The study focused on the following countries: Italy, Spain, Portugal, Belgium, Netherlands, Poland, United Kingdom and France.
As a reminder, electronic invoice was introduced at the European level by Directive 2001/115/EC as adapted by Directive 2006/112/EC (the VAT Directive). These directives deal with the requirements for issuing electronic invoices, but do not cover their communication to the tax authorities. Consequently, electronic invoices exist in all of the European countries and are often mandatory for public service contracts. However, reporting obligations to the tax authorities are much more heterogeneous.
Italy is currently the only country in Europe to introduce an obligation to issue electronic invoices coupled with reporting obligations to the tax authorities to strengthen VAT controls. Poland and France are expected to be next, given the legislation underway.
The other southern countries (Portugal and Spain) have already implemented stronger VAT controls, without relying on the general obligation to issue electronic invoices. These controls involve the frequent transmission to the tax authorities of electronic files of sales and purchases invoices created from records incorporated into their information systems. Poland also has a similar system based on SAF-T files.
For these countries and Italy, the tax authorities therefore have the means to carry out systematic automated controls of the VAT returns filed. We understand from our local contacts that these controls are not in place in Italy and to a lesser extent in Spain where VAT returns are pre-populated by the authorities (for companies with revenue > €6 million).
Lastly, the other countries examined (Germany, Benelux and the United Kingdom) are very minimalist on this issue, both in terms of the obligation to issue electronic invoices and regarding future goals for periodic transmission of electronic information enabling the tax authorities to enhance their controls.
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