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ViDA Analyzed – Part 2: 2 days deadline for the issuance of invoices on intra-Community supplies

Deadline for the issuance of invoices on intra-Community supplies of goods and supplies of services where the reverse charge applies: Article 222

In the case of exempted intra-Community supplies of goods and for services supplied by nonestablished taxable persons subject to the reverse charge, the VAT Directive provides for a deadline to issue an electronic invoice that could take up to forty-five days from the moment the chargeable event occurred.
The new reporting system is built under the philosophy of real-time information. Given that the reporting is based on the issuance of the invoice, such a deadline will delay excessively the arrival of the information on those supplies to the tax administration. For that reason, Article 222 sets up a deadline of two days after the chargeable event takes place for the issuance of invoices in these cases.

  • Article 222 the first paragraph is replaced by the following (applicable as of Jan 1, 2028)

‘For supplies of goods carried out in accordance with the conditions specified in Article 138 or for supplies of goods or services for which VAT is payable by the customer pursuant to Articles 194 and 196, an invoice shall be issued no later than on the fifteenth day of the month following that in which the chargeable event occurs.’


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