Comarch Data Exchange & Document Management Newsletter

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Comarch Data Exchange & Document Management Newsletter

New e-invoicing regulations are coming to Poland, Portugal, and Saudi Arabia!  

Poland – Implementation of B2B national e-invoicing platform

On February 5th the Ministry of Finance published a draft of the VAT Act amendment regarding the implementation of the National e-Invoice System called KSeF (Krajowy System e-Faktur). The new system will cover B2B transactions as of October 2021, at first on a voluntary basis. According to unofficial statements, the use of the new system is supposed to become mandatory as of 2023. The Polish e-invoicing system is going to be similar to the Italian clearance model (SDI), the Ministry says.

The proposed law introduces a new type of structured electronic invoices, which must be issued via KSeF.

Before starting to use an e-invoicing system, taxpayers will be obliged to notify the appropriate tax office and authenticate their own credentials with a qualified electronic signature or trusted profile (profil zaufany). Obtaining customer consent will also be required.

An application programming interface will make it possible to send e-invoices to KSeF, although micro-businesses will be able to issue e-invoices via a dedicated government web application called e-Mikrofirma.

After delivery to KSeF, e-invoices will be timestamped and assigned a unique identification number.

Among the benefits of the new system, the Ministry of Finance indicates unified e-invoices form and process standardization, secure storage of e-invoices in a central system for at least 10 years, exemption from sending Standard Audit Files JPK_FA and, after meeting certain criteria, a faster VAT return (40 instead of 60 days).

Portugal – Mandatory B2G e-invoicing

By January 1st, 2021, is was intended that mandatory B2G e-invoicing would apply to all enterprises. Due to the COVID-19 pandemic, the Portuguese Government decided to approve a set of extraordinary measures, including the postponement of the aforementioned obligation.

Currently only large companies must be ready to adopt B2G e-invoicing. The deadline for small and medium-sized enterprises has been extended to June 30th, 2021, while micro enterprises are required to start issuing B2G e-invoices as of January 1st, 2022 – a year later than previously announced.

Another challenge for taxpayers, regardless of format, is the obligation to use a single document code called ATCUD and add QR codes to all invoices and other fiscally relevant documents as of January 1st,2022. Requirements have been postponed for a year, although some enterprises may already use this system on voluntary basis. In order to further encourage taxpayers to implement the requirements more rapidly, the Budget State Law for 2021 introduced an extra Corporate Income Tax deduction of 20, 30 or even 40 % of expenses incurred during the adoption process of ATCUD and QR codes.

Saudi Arabia – Introduction of e-invoicing

E-invoicing regulations were introduced by the General Authority of Zakat and Tax (GAZT) on December 4th 2020, after being approved by its Board of Directors. Taxpayers are granted a period of 12 months to implement the provisions of the new regulations, ending on December 4th, 2021.
The new regulation applies to taxable persons, residents in the Kingdom of Saudi Arabia, and any third party that issues an invoice on behalf of taxpayers. Non-residents are exempt from the obligation.
Those subject to the new e-invoicing law must be able to issue electronic invoices and electronic notes (debit and credit), defined as documents generated in a structured electronic format through electronic means. No paper, copied or scanned invoices will be treated as electronic invoices and, will no longer be accepted.
Although the technical specification has not yet been published, GAZT has introduced a number of basic requirements regarding the issue of electronic invoices.
The implementation process is divided into two phases. Phase one is focused on generating and storing e-invoices, while the second phase covers the integration of a taxpayers’ solution with the GAZT system. Both will be described in upcoming resolutions, which are expected to be introduced no later than June 2021.


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