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Draft regulation of the Create and Grow Law

  • The draft regulation of the Create and Grow Law has undergone many modifications and leaves many aspects open.
  • It goes against the spirit and letter of a recommendation for electronic invoicing.
  • The platform for exchanging invoices will only accept invoices in XML Facturae format, which goes against the European Union Implementing Decision 1870/2014.
  • The regulation does not solve the problem of the directory of entry points for companies.
  • The standard admits the use of CII and UBL formats, EDIFACT, and XML Facturae.
  • Invoices sent through the Tax Agency platform have to be signed, which goes against the electronic invoice directive.
  • The draft does not specify how the operators should connect, only that if they do not agree they will have to do it through the AEAT.
  • Three mandatory states to communicate are established, but it is not obligatory to communicate the receipt.
  • When the AEAT platform is used, a ministerial order for future publication must be referred to.

Source Sergio Ramon Ruiz Mahillo

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