Zasielanie údajov z faktúr daňových subjektov finančnej správe ( „Real-time invoicing")

Real-time invoicing

As we have previously informed you in Tax and Legal News 1-2/2021, the Ministry of Finance of the Slovak Republic is preparing legislation to implement a new mandatory system of reporting real-time data from both issued and received invoices to the Slovak Financial Administration (SFA). This aims to combat tax fraud and decrease the Slovak VAT gap, as well as gap in  corporate and personal income tax. Current control mechanisms (in particular, the VAT ledger) appear to be ineffective, specifically due to the time lag between completion of a transaction and its reporting to the relevant tax authority.

• What obligations should the new legislation impose?
  • Prior to an invoice being issued, specific details will have to be sent to the Slovak Financial Administration If invoices are issued using accounting software, this will have to be recoded to enable the issuing process to be paused, while the SFA verifies the final data. After verification is complete, the SFA will generate a token (presumably in the form of a QR code) for the taxpayer to add to the invoice, which can then be issued and send to the invoice recipient.
  • Invoice recipients will also need to send data from received invoices to the SFA (a token should be sufficient) before the taxpayer is able to exercise the right  for a VAT deduction based on the received invoice, or include such invoicing tax-deductible expenses.
  • The obligation of VAT payers to file  VAT Ledgers should be cancelled, as the SFA will have all the real-time data from invoices available by the time of their issuance.

• Which entities will be subject to the new obligations?
  • The requirement to send invoice data to the SFA, before it can be issued, will be extended to all business entities and not only VAT payers.
  • There will be certain exceptions, for example, if a transaction is registered in the ERP system  after the receipt of sales revenues at the point-of-sale.
• When will these obligations be introduced?
  • The obligations are expected to take effect from 1 January 2023 at the earliest.
  • Gradual phased implementation is under consideration, possibly beginning with a pilot scheme using a sample of different types of entrepreneurs.

• What is the solution for companies which either cannot modify their IT systems, or for which this is excessively expensive?
  • A system solution is being developed by our specialists who have both tax expertise and IT resources at their disposal. This solution is in the form of an application installed on the taxpayer’s hardware (an on-premises solution, under the taxpayer’s full control) and self-managed by the taxpayer via a website.
  • The solution will be compatible with accounting software (its billing module).
  • It includes updates for legislative changes and provides immediate support in the event of either routing problems or major accidents.
  • If you would like to learn more about our upcoming solution, please do not hesitate to contact us.

We will update you on the draft law as soon as its detailed wording is known as part of the official commenting process, which is expected to begin during the summer.

Alica Demitrovičová

Juraj Ontko