Greek Tax Administration goes Digital • e-books • e-invoicing • Connected Electronic Tax Register Machines (ETRMs)
Upon public consultation with the key market players as well as competent regulatory bodies and as the amendment of the respective tax provisions, the Ministry of Finance (MoF) and the Independent Authority of Public Revenues (IAPR) have issued the essential decisions regarding the implementation within year 2020 of e-books, e-issuance of wholesale and retail sale records (einvoicing) through licensed providers, the upgrade of ETRMs for retail sales, which will be subsequently connected on-line with IAPR, as well as of e-invoicing for public contracts (B2G).
e-books_data transmission myDATA platform
The requirement for the e-books’ data transmission commences as of October 1st 2020, while the data of the preceding 9month period will also be transmitted retroactively.
• Pursuant to L. 4646/2019, Tax Procedures Code (TPC) has been amended and the mandatory digital transmission of entrepreneurs’ data ( issued accounting records, accounting books as well as ETRMs data) to myDATA platform, developed by IAPR, was introduced.
• Decision A.1138/2020 determines the scope, timeline and digital transmission process of the entrepreneurs’ data to IAPR. The respective technical requirements as well as the operational details of myDATA platform have been uploaded to IAPR website at www.aade.gr/mydata.
• The entrepreneurs are liable to digitally transmit their transactions’ data as well as the accounting and tax classification of their revenues & expenses as of October 1st 2020.
• The deadlines for the data transmission and for the classification thereof are defined in the aforementioned Decision. Indicatively, the revenues’ data and classification are required to be transmitted on real time while certain exceptions are itemized in the Decision (e.g. for year 2020 the revenues’ data are transmitted at the latest by the 20th day of the following month).
• In the event that e-invoicing via licensed providers has been opted, the entrepreneurs’ data are transmitted to myDATA platform as of July 20th 2020. The transmission of accounting and tax classification thereof may also voluntary initiate as of the same date.
• For the first year of implementation (2020), as regards the data issued as of 1.1.2020 and up to 30.9.2020, the main deadlines for the transmission of the data and classification thereof are:
• for revenues, by 31.12.2020 (unless the respective data have already been transmitted through licensed providers); •for expenses, by 28.2.2021;
• for the expenses which were not transmitted by the liable to do so issuer up to 31.12.2020 as ought, the recipient proceeds to their transmission during 1.1.2021 28.2.2021.
• for the payroll entries, by 31.12.2020.
• The accounting and tax classification of the transmitted data is obligatorily performed by a licensed accountant.
e-invoicing through licensed providers
e-invoices via licensed providers are anticipated to be issued as of July 20th and onwards.
• L.4646/2019 has also amended L. 4308/2014 providing businesses with the option to issue e-records for wholesale and retail sales (e-invoicing) through licensed providers; the latter apart from securing the authenticity of sales records will also digitally transmit the content thereof to myDATA platform.
e-invoicing through licensed providers is optional, while tax incentives are to be provided to entrepreneurs who will opt to implement.
• In an effort to attract more entrepreneurs to e-invoicing through licensed providers, the MoF and IAPR are contemplating the grant of tax incentives, under prerequisites, such as:
• reduction of the statute of limitation by 2 or 1 years, depending on whether the company will initiate the issuance or consent to receipt of e-invoices through licensed providers, respectively; •tax super deduction by 100% of the initial equipment and software purchase as well as the respective e-invoicing issuance expenditure for the first year;
• reduction of the tax refund timeline to 45 days, from 90 days which is stipulated in TPC.
•The relevant incentives have been incorporated in a draft bill which is expected to be voted the forthcoming days.
ETRMs upgrade and on-line connection with IAPR
The existent active ETRMs, are required to be updated, if needed, by 31.7.2020, in order to be compatible with the additional technical requirements set forth.
The timeline for on-line connection of ETRMs with IAPR is to be determined.
•Pursuant to L. 3842/2010, taxpayers are required to digitally transmit to IAPR information systems the data of the issued accounting records, irrespective of their issuance method.
•IAPR Decision Α.1024/2020 has provided for supplementary technical specifications for ETRMs with respect to data transmission and, among others, refer to the required capability of the latter to transmit data on real time or at the latest within 24 hours.
• Furthermore, pursuant to IAPR Decision A. 1102/2020, the entrepreneurs are obliged to upgrade their ETRMs in order for the latter to be compatible with the updated technical specifications by 31.7.2020.
• The timeline for the online connection of ETRMs with IAPR information systems and the data transmission commencement are pending to be determined. •As determined by Decision A.1138/2020, in case an online connection requirement with IAPR exists, such is the only permissible option for retail sales data transmission to myDATA platform.
e-invoicing for public contracts (B2G)
e-invoicing for public contracts (B2G) will be optional for now, while it is contemplated to be set as obligatory in the future. Pilot e-invoicing for public contracts (B2G) is expected to initiate at the last quarter of year 2020.
• Under L. 4601/2019, EU Directive 2014/55/ΕΕ has been incorporated in Greek legislation as regards e-invoicing for public contracts exceeding the set per case value thresholds, excluding VAT.
• Joint Ministerial Decision 60967 ΕΞ 2020 has determined the architecture, the e-invoicing receipt, process and payment procedures, the interoperability and interconnection requirements with the integrated public information systems, the technical requirements as regards security and data protection as well as any other technical aspect thereof.
• Joint Ministerial Decision 60970 ΕΞ 2020 has determined the national e-invoicing format for public contracts; as of its entry into force (18.6.2020) and up to 31.12.2020, the Public Contracting Authorities/ Bodies are obliged to proceed to the required technical adjustments of their information systems.
• As stated in a public announcement of the MoF, e-invoicing for public contracts will initially be optional. Nonetheless, it is contemplated to become obligatory in the future for all Greek State suppliers. Pilot implementation of e-invoicing for public contracts (B2G) is anticipated during autumn of year 2020.
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