E-Invoicing – Governments Enforce Adaption

Based on the provisions of Section5 of the Austrian ICT Consolidation Act (IKTKonG) the federal government departments only accept electronic invoices. The features required for submitting e-invoices are also available to other public sector institutions.

Invoice Recipients

Via E-RECHNUNG.GV.AT it is possible to transmit electronic invoices to the federal government and to connected institutions of other parts of the public sector. The national XML standard ebInterface or the international Peppol UBL standard can be used as invoice format.

Invoice Recipients of the Federal Government

Based on the provisions of Section 5 of the Austrian ICT Consolidation Act (IKTKonG), the Austrian federal government only accepts electronic invoices (e-Invoices) for the provision of goods and services. The federal government institutions are:

• All ministries and their subordinated administrative offices
• The Parliament
• The office of the federal president
• The higher administrative court
• The constitutional court
• The Austrian ombudsman board
• The court of audit

Invoice Recipients of Other Public Sector Institutions

A detailed listing of all invoice recipients of other public sector institutions connected to E-RECHNUNG.GV.AT is also available. Currently there is no legal obligation for e-invoices to be used for the institutions of the other public sector.

For Contracting Partners of the Public Sector

1. In order to be able to transmit e-invoices companies need to register once (free of charge) at the USP (User Service Portal - see www.usp.gv.at). Suppliers who submit their invoice through a third party or use the Peppol transport infrastructure do not need to register at the USP.
2. After registration and login at the USP and accessing ‘E-RECHNUNG.GV.AT’ (under ‘My Services’) the next page will be shown
3. To transmit an e-invoice by using one of the supported delivery methods certain invoice data is mandatory

Within the Public Sector

1. Other public sector institutions have to embed the functions of E-RECHNUNG.GV.AT into a public sector portal (PVP) in order to be able to transmit e-invoices
2. After registering an authorized employee at the portal Austria (PAT) e-invoices can be submitted by using one of the supported delivery methods. Certain invoice data is mandatory.

Peppol (Pan-European Public Procurement OnLine)

Peppol enables electronic public procurement procedures (Public eProcurement) within the European Union across borders.

The purpose of Peppol is that every company in Europe – regardless of size – can exchange electronic messages with any public client and any private company that also participates in any EU country on the basis of this standardized.

In the context of public procurement, Peppol is an important step towards e-invoicing, which enables high cost savings due to faster accounting processes with fewer errors due to manual interaction and uniform data management.

The Peppol transport infrastructure is based on various technical specifications, technical standards and business processes. 

By connecting to the SEEBURGER Open Access Point for Peppol starting Q4 2018, companies can easily send invoices to all public administrations in Austria that also use the Peppol network.

SEEBURGER E-Invoicing Cloud Service for Austria – B2G over ebInterface or Peppol:

When booking the SEEBURGER E-Invoicing Cloud Service for Austria, SEEBURGER customers can choose their preferred connection option (via ebInterface or Peppol).

All B2G (Business to Government) or G2G (Government to Government) e-invoices in France will be centralized on a unique platform, Chorus Pro. Chorus Pro is developed and operated by AIFE (French Government’s Financial Information Technology Agency).

All B2G (Business to Government) or G2G (Government to Government) e-invoices in France will be centralized on a unique platform, Chorus Pro

• Chorus Pro is developed and operated by AIFE (French Government’s Financial Information Technology Agency)
• Subcontractors admitted to the direct payment of contracts concluded by the State, local authorities and public establishments transmit their invoices in electronic form
• State, local authorities and public institutions accept invoices sent in electronic form. Ultimately all the approx. 78,000 public administrations in France will exchange approximately 100 Million invoices per year over the Chorus Pro Platform.

The Chorus Pro Portal:

• Reduces costs and processing times which lead to productivity gains for both companies and the client entity
• Secures the exchanges
• Works for sustainable development (reduction of CO2 emissions, paper, means of transport, etc.)
• Is completely free

Who is obliged to follow Chorus Pro?

• January 1^st, 2017: for large companies
  • (> 5000 employees or annual revenue > 1.5B €)
• January 1^st, 2018: for medium-sized businesses
  • (250 <> 5000 employees or annual revenue 50M € <> 1.5B €)
• January 1^st, 2019: for small and medium-sized businesses
  • (10 <> 250 employees or annual revenue 2M € <> 50M €)
• January 1^st, 2020: for microenterprises
  • all others included “1-person” businesses

Accepted E-Invoice Formats on Chorus Pro

• Structured invoice formats: UBL (FEN105), CII (FEN135) plus syntax from the European Standard
• PDF invoices (signed or unsigned), which suppliers upload to the Chorus Pro platform. On the platform, the data of the PDF invoices are read out through an OCR. The supplier then has to check the results of the OCR and correct them manually.
• Online invoicing on the Chorus Pro Platform
• Light XML with an embedded PDF invoice
• Hybrid Invoice FACTUR-X

All B2B (Business to Business) e-invoices in France need to comply with the DEMAT requirements.

For EDI DEMAT compliant e-invoicing this means:

• EDI DEMAT compliance of invoice content: Invoices must contain the mandatory information required by DEMAT regulations in the corresponding data fields.
• Accepted e-invoice format for EDI DEMAT is EDIFACT D96A.
• Invoice summary list: A sequential summary of the invoices must be created and built up, as messages are sent or received and must not be modifiable.
• Partner list: A file of partners with which the company exchanges invoices electronically must be created.
• Electronic archiving is required:
  • The electronic invoice needs to be archived.
  • In addition an invoice summary list and a partner list need to be archived.
  • Archiving periods are:
    • Tax authorities requires six years after expiration of the current financial period.
    • Commercial law dictates a period of ten years for archiving of documents.
    • Location of storing can be either domestic or outside of French territory
      • If in Europe but outside France: customer must specify this to French tax authorities.
      • If outside of Europe: the respective country must have signed an agreement with French tax authorities (USA or Turkey haven’t signed it, for example).
  • Tax Authorities must be granted online access for downloading – for control purposes – and for use of the data stored, regardless of the place of storage or  the person responsible for storing.

Who is obliged to follow DEMAT compliant E-Invoicing?

• EDI DEMAT E-Invoicing is not mandatory so far.
• But when French business partners agree on EDI DEMAT for domestic invoices, they need to follow the rules of French dematerialization.

SEEBURGER has renewed its qualification issued by GS1 for EDI electronic invoicing according to DEMAT in April 2018. The GS1 qualification identifies solutions that meet the demands of the market.

Obligation to receive and process electronic invoices by the public administration.

The E-Rechnungsgesetz law transposes the provisions of European Directive 2014/55/EU of 16 April 2014 into national law in Germany. The E-Rechnungsgesetz thus creates a binding legal basis for the receipt and processing of electronic invoices by public authorities.

XRechnung is the national version of the European Standard for German Administration and published by the Coordination Office for IT Standards (KoSIT).

Implementation dates of the EU Directive in Germany

The Federal E-invoice Ordinance adheres to the original implementation deadlines laid down in the EU Directive, i.e..:

• 27 November 2018 for federal public-sector clients
• 18. April 2020 for decentralised public clients of the Federal Government.

Obligation to send E-Invoices to public authorities

Based on the recital of the EU directive, the federal government is introducing an e-invoicing obligation for suppliers – like other EU states – as of 27 November 2020.

Exceptions are:

• de minimis limit
• Defence and security-related contracts
• Organ loans of the federal states

UN/CEFACT and UBL, the two obligatory syntaxes for public administration

According to the implementing decision of 16 October 2017 of the European Commission, the following two syntaxes for reception and further processing are mandatory for public administrations:[1]

• UN/CEFACT Cross Industry Invoice XML message according to XML Schemas 16B (SCRDM - CII)[2]
• UBL for invoices and credit notes according to ISO/IEC 19845:2015[3]

ZUGFeRD: B2B- B2G- E-Invoicing, the cross-industry hybrid invoice

UN/EDIFACT as a global standard is the world's most widely used standard in business in the B2B sector. In addition, the cross-industry hybrid format ZUGFeRD has been established in the B2B sector since 2014. ZUGFeRD offers small and medium-sized companies in particular the invoice as an image (PDF-A/3) and as a machine-readable E-Invoice data record as an XML file based on the Cross Industry Invoice XML from UN/CEFACT. The Forum elektronische Rechnung Deutschland (FeRD) of AWV - Arbeitsgemeinschaft für wirtschaftliche Verwaltung e. V. is the publisher of the ZUGFeRD standard.

XRechnung and EU invoice to public authorities

The latest ZUGFeRD version 2.0/Factur-X conforms to the European standard (EU invoice) and thus enables B2G e-invoicing ("calculation").

In addition to the joint German-French standard Factur-X / ZUGFeRD 2.0, the German specification XRechnung for public authorities is also based on the European standard – Electronic Invoice; both standards form two so-called core invoice usage specifications ("CIUS").

In accordance with the Federal E-Invoice Ordinance, an E-Invoice must always be submitted as an XRechnung or as an EU-Invoice.

XRechnung – the Core Invoice Usage Specification (CIUS) of the European standard for E-Invoicing for public administration in Germany

Just like Factur-X/ZUGFeRD 2.0, the XRechnung is also a CIUS and represents the European standard for electronic invoicing for administration in Germany and supplements it with further national regulations relevant for administration in Germany, e.g. by upgrading optional fields to mandatory fields. This enables the administration to specifically request necessary information in an invoice that is important for invoice processing in the administration. The European specifications are adapted to national requirements by means of XRechnung.

The central invoice receipt portal of the Federal Government for E-Invoices in Germany

The E-Invoice must be submitted via a central federal E-Invoice portal:

• manual entry in the web form
• file upload
• e-Mail
• De-Mail
• Web service interface/Peppol

Real-Time VAT Reporting is mandatory in Hungary for invoices issued between domestic taxpayers in which there is 100.000 HUF/320 € or more charged tax

• The National Tax and Customs Administration of Hungary (Nav Nemzeti Adoes Vamhivatai) uses a system called KOBAK for this purpose.
• Tax payers have been required to transmit VAT data on invoices issued in real-time (Real Time Invoice Reporting (RTIR)) via the KOBAK system of the NAV since 01. July 2018.
• Changes 2019 and 2020
  • The initial version 1.0 can only be used until 04. Juni 2019, 03:59. Version 1.0 data will then be rejected by NAV.
  • The upgrade from version 1.0 to 1.1 can take place any time as they work in parallel until 04. Juni 2019, 03:59.
  • There is also a version 1.2 on the roadmap which may run in parallel to version 1.1. The specifications for the versions are made available at https://onlineszamla.nav.gov.hu/dokumentaciok.
  • Versions 1.1 and 1.2 are expected to be uniformly replaced by the new interface version 1.3 due at the 01. January 2020.

Reasons for Hungary Introducing VAT Reporting

• A large amount of invoice turnover becomes visible in real-time for the National Tax Authority (NAV)
• NAV can perform risk management on taxes more effectively
• Increase of VAT revenues by prevention of fraud

NAV – General Information

• The requirements by NAV on this mandate have changed recently
• Usually, when such new processes and systems are launched in a country they include changes to due dates, penalties, formats, notifications, etc. and this often happens in the beginning
• Therefore, all information provided here regarding the VAT-reporting in Hungary represents the current SEEBURGER knowledge based on an intensive dialogue with the appropriate authorities

B2T E-Invoicing in Hungary with the NAV KOBAK-System

The National Tax and Customs Administration of Hungary (Nav Nemzeti Adoes Vamhivatai) provides complementary services for the taxpayer to ease the operation and upgrades of versions:

• Immediate and automatic notification after you sign up for updates, version changes, or any errors
• Statistics on the taxpayer's monthly data transfer, its erroneous data deliveries and its quality
• A query option for the interface that allows a particular content to be tested for errors in a test-environment

Deadlines for VAT Registration of Issued Invoices to NAV

• Amounts lower than 100.000 HUF: No VAT reporting to NAV required
• An invoice must be created no later than the 15^th day after the services or goods have been delivered
• The report to NAV must take place immediately after "technical creation" of an electronic invoice
• Exceptions for invoices in printed predefined or handwritten formats e.g. cab or restaurant bills:
  • Amounts between 100.000 HUF to 499.999 HUF reporting to NAV within 5 days after the invoice issuance for invoices with VAT
  • Amount 500.000 HUF or higher reporting to NAV within 24 hours after the invoice issuance for invoices with VAT

Penalties for Noncompliance  

Up to 500.000 HUF/1.600 € for each invoice can be charged when obliged taxpayers do not report via NAV.

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SEEBURGER’s solution is able to accommodate the E-Invoicing requirements of Italy, comprising:

Fattura PA B2G and upcoming B2B

With the passing of the 2018 Budget Law, mandatory electronic invoicing between private companies has finally been approved in Italy. It becomes mandatory for domestic B2B and B2C invoices.

Established already in March 2015

• Italy was one of the pioneers in putting the E-Invoicing EU Directive into practice with the Exchange System ‘Sistema di Interscambio’ (SdI). This is based on the FatturaPA specification.
• FatturaPA is the only type of electronic invoice that will be accepted by Public Administrations (PA) which, according to the Law, are obliged to make use of the Exchange System
• Since then already millions of  B2G electronic invoices have been sent to PA
• FatturaPA XML is the mandatory XML format which needs to be signed with a certified XAdES-BES signature
• SdI offers communication channels for automated integration (e.g. Web Services and FTP) and a web interface for manual uploads
• FatturaPA invoices must be stored in the same way as any other electronic B2B invoice in compliance with Italian law

Current state
Since January 1^st 2017

• FatturaPA XML’s transmitted via SdI can be used for E-Invoicing between business partners of the private sector (B2B)
• For B2B the usage of SdI is optional, and – when practiced – reduces existing reporting obligations
• Per quarter, approximately 5,000 B2B invoices have been exchanged electronically via SdI – as there was no obligation to use it

With the passing of the 2018 Budget Law, mandatory electronic invoicing between private companies has finally been approved in Italy. It has become mandatory for domestic B2B and B2C invoices:

Since July 1^st 2018

• Services rendered by subcontractors in the supply chain of companies participating in contracts with a public administration

Since September 1^st 2018

• Tax-Free Shopping
  • A regular invoice is issued
  • The goods are transported in personal luggage outside the European Community within 3 months of purchase
  • The goods are intended for personal or family consumption
  • The goods are purchased by a private citizen
  • The new obligation affects electronic invoicing for selling goods (not services) exceeding the 155€ threshold (including VAT), resulting from a single invoice at the same point of sale
  • There is a tax advantage reserved for people living outside of the European Community, that allows them to be reimbursed for VAT paid on purchases made in Italy

Since January 1^st 2019 

• Supply of petrol or diesel intended for use as motor fuel
• All other business-to-business transactions

Every invoice from an Italian supplier to an Italian buyer must be submitted in FatturaPA format via the SdI exchange system before it will be considered as issued from a tax perspective. With this obligation Italy will operate very similarly to Clearance countries such as Mexico, Turkey etc.

E-Invoicing in Mexico with CFDI 3.3 and New Complement for Payments.

Mexico Introduced the CFDI Format Back in 2011 Which Is Mandatory for Most Electronic Invoices

CFDI stands for ‘Comprobante Fiscal Digital por Internet’ – literally translated as a digital fiscal document via Internet (bill). The CFDI invoice must contain both the signature of the exhibitor and the signature of a certification provider PAC ‘Proveedor Autorizado de Certificación’. The PAC must be authorized by the Mexican Tax Authority (SAT).

There are four types of CFDI’s: invoices, direct debits, credits and bills of lading. The CFDI tipoDeComprobante attribute can have the following values for this purpose:

• ‘Ingreso for facture’ (invoices) oder ‘nota de cargo’ (direct debits)
• ‘Egreso for nota de crédito’ (credits)
• ‘Traslado for carta de porte’ (bills of lading)

The CFDI version 3.3 including ‘payment complemento’ and the ‘buyer’s approval of CFDI cancellation’ became mandatory in the course of 2018.

The Spanish Tax Agency initiates a new VAT management system based on information from business transactions (AEAT = Agencia Estatal de Administración Tributaria / State Tax Administration Agency) in real-time.

On July 1st 2017 the Spanish Tax Agency Initiated a New Vat Management System Based on Information from Business Transactions Called Aeat

• AEAT stands for Agencia Estatal de Administración Tributaria / State Tax Administration Agency in real-time. The technical system enabling it is  called SII (Immediate Information Sharing System).
• Currently this process will only be required for 63,000 taxpayers consisting of large companies, VAT groups and those registered in the monthly refund regime
• Advantage for the companies:
  They will have an additional 10 days for self-assessments and will not file forms 340 (register books), 347 (transactions with third parties) or 390 (annual summary)
• With the information received and the information contained in the database, the Tax Agency will prepare the taxpayer's tax data, for VAT purposes, thus facilitating the tax return

Who Is Obliged to Follow SII ?

• Large companies (more tan 6M € of annual turnover)
• Companies registered in the monthly VAT return (REDEME)
• VAT Groups
• Small and medium companies may join the system voluntarily. They are accepted based on a census declaration in December of the previous year.
• This sums up to approx. 62,000 companies which make up 80% of the total VAT invoicing in Spain

Relevant messages and their deadlines for registration in SII

• Invoice issued: Deadline of 4 calendar days from the issue of the invoice or from the date on which the accounting entry is made
• Invoice received
  • Deadline of 4 calendar days from the date of the accounting entry for the invoice, in any event, by the 16th day of the month following the liquidation period in which the relevant operations are included
  • For imports, the 4 calendar days must be counted from the accounting entry of the document which records the amount paid to Customs (the DUA) and, in any event, by the 16th day of the month following the liquidation period in which the relevant operations are included

Penalties will be charged from  January 1^st 2018 when obliged taxpayers do not report via SII.

Based on the legal provisions in Law 25/2013 establishing the obligation of the electronic invoicing for the Spanish government departments, regional authorities and local authorities only accept electronic invoices. Since 2015 this applies to all invoices exceeding EUR 5,000. The public sector may only accept paper invoices below EUR 5,000.

Invoice Recipients

Via the FACe GATEWAY – https://www.facturae.gob.es/Paginas/index.aspx – it is possible to transmit electronic invoices to the federal government and to affiliated institutions of the public sector. The national XML standard Facturae with an eSignature according to the XAdES standard needs to be used as the invoice format.

Invoice Recipients of Other Public Sector Institutions

FACe is the only entry point for e-Invoices to the central government in Spain. Local and regional governments are free to develop their own solutions or leverage a solution from other administrations; typically they also use FACe. All e-Invoice receiving systems are integrated into the Accounting Register of Invoices, which controls the payment process centrally.

Electronic invoicing services offered by FACe can be accessed via the platform portal. To support the direct integration of applications for invoice processing, a web services interface is available.

For Contracting Partners of the Public Sector

Suppliers can use FACe as the ‘Yellow pages’ of the public sector to look up the E-Invoicing addresses of a public administration (including those not associated with FACe).