Global Comparison of Prefilled VAT Return Systems

Adoption Status: Implemented, Pilot, or Planned

• Latin America: Chile was a trailblazer, launching prefilled VAT return proposals in 2016 and fully rolling them out by 2017–2018. Several other Latin American countries followed. For example, Mexico’s tax authority (SAT) introduced an automated VAT return module in early 2024, using e-invoice (CFDI) data to prepopulate monthly VAT filings. Peru has for some time prefilled portions of the VAT ledgers (sales and purchases books) from its electronic reporting system. Bolivia (with its SFE e-invoicing from 2021) and others in the region likewise leverage their e-invoicing systems to generate draft returns. Argentina is in the process of implementing “IVA Simple” – a simplified, prefilled VAT return system that replaces multiple forms with one auto-completed form (Form 2051). IVA Simple was piloted from June 2025 and becomes mandatory from November 2025. [vatupdate.com], [vatupdate.com] [ey.com] [sovos.com], [sovos.com] [vatcalc.com] [vatupdate.com]
• Europe: The European Union sees prefilled VAT returns as a next-step in digital tax reporting. Starting in late 2020 and 2021, several European countries launched prefilled return initiatives.
  • Italy was one of the first in the EU – since 2021 the Italian tax authority has offered pre-populated periodic VAT returns (for quarterly filings), and in 2023 it even made a prefilled annual VAT return available to millions of taxpayers based on 2022 data.
  • Spain introduced a helper service called “Pre303” in 2020–2021 to pre-complete the periodic VAT form (Modelo 303) for businesses reporting invoices in real time via the SII system.
  • Greece made prefilled VAT returns available in late 2022 using data from its myDATA e-books platform.
  • France began auto-populating certain fields of the VAT return in 2022 (for import VAT) and plans to expand prefilled returns once its domestic e-invoicing mandate is in effect (scheduled from 2026). Smaller European nations have joined in:
  • Hungary launched an “eVAT” platform in January 2024 to provide prefilled VAT returns drawn from its live invoice reporting system;
  • Portugal has gradually introduced pre-population (since 2020 for some taxpayers, with plans for prefilled annual filings using SAF-T data by 2025);
  • Romania implemented prefilled VAT returns in mid-2024 as part of its e-invoicing rollout.
  • Several others are in pilot or planning stages –
  • Croatia aims for prefilled returns by 2026 alongside e-invoicing,
  • Serbia will introduce them by 2026 via its new e-invoice system, and
  • Slovenia is slated to launch prefilled VAT returns in 2025.
  • Even Albania (which fiscalized all invoices in 2021) automatically generates VAT returns from its e-invoicing data since 2022. [sovos.com], [sovos.com] [asesoriaga…ialopez.es] [sovos.com] [vatcalc.com] [vatupdate.com], [vatupdate.com] [vatcalc.com] [vatcalc.com], [sovos.com] [sovos.com], [sovos.com]
• Asia & Africa: In the Asia-Pacific region,
  • India’s GST system has offered auto-populated GST returns for a few years. Data from sales and purchase invoices (GSTR-1 and GSTR-2B) flows into the summary return (GSTR-3B), giving taxpayers a prefilled starting point. This is continually being tightened – for example, from Jan 2025 India will “hard lock” certain data (so what’s reported in the sales return can no longer be edited in the summary return) to ensure the prefilled figures are used.
  • Indonesia enabled prefilled VAT returns in 2020 with its e-Faktur 3.0 system, which automatically populates the VAT return for businesses required to use e-invoicing.
  • China has reportedly experimented with “profiled” VAT returns for certain taxpayers, using sales and purchase data the tax authority already has. In Africa,
  • Kenya introduced prefilled VAT returns starting with the February 2024 period, leveraging data from its new electronic invoicing regime (TIMS) to populate taxpayers’ monthly VAT forms. A number of other countries across Eurasia and Africa have either limited prefill programs or plans in progress – for instance,
  • Uzbekistan, Tajikistan, and Armenia have announced projects to pre-complete VAT returns using purchase/sales invoice data. In summary, the trend is global and growing, often aligned with broader digital reporting mandates. Even the EU is considering allowing or encouraging prefilled VAT returns union-wide as part of the proposed “VAT in the Digital Age” reforms by 2030. [sovos.com] [sovos.com], [sovos.com] [vatcalc.com]

Taxpayers and Transactions Covered

• By size or filing status: Spain’s Pre303 service initially applied only to firms in the SII (Immediate Supply of Information) system – primarily large companies (turnover > €6M) and those in the monthly refund regime (REDEME), who must file VAT monthly. Smaller Spanish businesses filing quarterly were not using SII, so they didn’t receive prefilled drafts at first. (Spain later extended Pre303 to a broader set of SII participants, including virtually all companies enrolled in SII regardless of size.) Italy’s prefilled return program initially excluded certain special regimes and large companies: the service in 2021–2022 was available to resident taxpayers on quarterly VAT filing, mostly SMEs, and specifically not available to sectors with complex VAT regimes (publishing, second-hand goods, travel agencies, etc.) or to non-resident VAT registrants. This meant Italy started with a subset (about 2.4 million taxpayers) rather than everyone. Hungary’s new eVAT platform, on the other hand, is open to all taxpayers, small or large, including foreign companies registered for VAT in Hungary – but with different usage modes for small vs. large (discussed later). [asesoriaga…ialopez.es] [sovos.com], [sovos.com] [sovos.com] [vatcalc.com], [vatcalc.com]
• By voluntary vs mandatory: Some early implementations have been optional. Hungary’s eVAT in 2024 is initially voluntary – taxpayers can choose to use the prefilled return portal or continue filing returns the old way (the traditional return filing system remains available). Italy’s prefilled annual return was effectively optional in its first year; eligible taxpayers could log in and use the prefilled declaration, but they could also continue filing their VAT returns through their own software if they preferred (Italy “allowed” taxpayers to download the prefilled return, rather than forcing them to use it). In Argentina, the IVA Simple system had an optional transition period (from June to October 2025) before it becomes mandatory for all VAT payers in November 2025. In contrast, some countries make the prefilled return effectively the default method once launched – e.g. Chile’s system is the standard for all, and taxpayers just log in to see their prefilled Form 29 each month. Romania in 2024 requires all VAT-registered businesses to submit the new prefilled form (alongside their own form) from day one, leaving no one out (though this approach has drawn criticism for being rushed). [vatcalc.com], [vatcalc.com] [sovos.com], [sovos.com] [vatupdate.com] [vatupdate.com], [vatupdate.com]

• Domestic sales and purchases: In Chile, the prefilled VAT return pulls data from all electronic sales and purchase invoices and credit notes reported in the monthly ledger (Registro de Compras y Ventas, populated via the e-invoicing system). This covers taxable sales, customer invoices, supplier invoices for input tax, and any credit or debit notes. Mexico’s new system automatically fills in sales and expense information based on all CFDI invoices issued and received, distinguishing those paid in full vs. in installments (using payment codes on the invoices). It even accounts for credit/debit notes and cancellations, integrating those into the draft figures. In Italy, the quarterly prefilled returns and the annual return use data from the electronic invoice platform (SDI) and the daily store receipts (for retail sales) that are transmitted to the tax authority. That means Italy’s draft includes B2B invoices, B2C receipts, and it even carried forward prior-year credits or payments on account known to the authority. Spain’s Pre303 draws on the invoices the business itself reported via SII – essentially all sales invoices issued and purchase invoices received that were uploaded within the required 4-day window. Thus, for those in the system, the draft return reflects their own submitted invoice data (ensuring, in theory, that the tax due matches the transactions they reported). [vatupdate.com] [ey.com] [sovos.com] [asesoriaga…ialopez.es], [asesoriaga…ialopez.es]
• Cross-border and special transactions: Some regimes incorporate import VAT and other less common items. For instance, France’s pre-population (since 2022) focuses on import VAT – the French VAT return now comes with the import VAT amount already filled in based on electronic customs declarations. (Domestic sales/purchases in France won’t be prefilled until e-invoicing data becomes available to the tax authority, which is planned for 2026.) Hungary’s eVAT aggregates data from multiple sources: the real-time invoice reporting system (for domestic B2B and certain B2C invoices), the online cash registers (for retail sales), and customs records (for imports). Romania likewise plans to use data from its various e-systems – e-Factura (invoices), e-Transport, SAF-T accounting reports, cash registers, and customs – to fill in different fields of the return. Generally, any transaction that a taxpayer would normally have to report on their VAT return (taxable sales, exports, imports, domestic taxable purchases, etc.) is a candidate for prefill if the tax authority has the information electronically. For example, Chile’s system, after years of data gathering, was able to eliminate the need for taxpayers to keep separate purchase and sales ledgers because the authority already has all that info and uses it to prepare the return. That said, there are limits: transactions outside the e-invoicing net may not be prefilled. In France currently, domestic transactions still must be entered by taxpayers. In many countries, certain adjustments or special regime calculations (like flat-rate schemes, margin schemes, etc.) are not handled by the prefill and must be added by the taxpayer if applicable (Italy, for example, excluded the sectors under special VAT regimes from the prefilled program, as noted). [sovos.com] [vatcalc.com], [vatcalc.com] [vatupdate.com] [vatupdate.com], [vatupdate.com]
• Frequency and timing of issuance: Nearly all these systems generate prefilled returns on the same schedule as the regular VAT filing frequency. If a business files VAT monthly (common for large businesses) or quarterly (for smaller ones in some countries), the tax authority will provide a draft for each period. For instance, Spain produces a Pre303 draft each month for SII participants (since those participants file monthly by law). Italy provided prefilled quarterly VAT liquidation statements to eligible taxpayers, and later an annual VAT declaration; in 2023, Italy’s annual draft for the 2022 tax year was made available on 15 February 2023, well ahead of the 2 May filing deadline for that year. In Hungary’s eVAT, the portal is continuously populated with live data; taxpayers could start reviewing January 2024 transactions in real time, but the actual first submission of a prefilled return was for the January period, due in February. Thus, the draft “appears” essentially as soon as the period ends (or even progressively builds up during the period), and taxpayers can then approve and submit it by the normal due date. In short, the prefilled returns are issued on a recurring basis (usually monthly/quarterly) shortly after each tax period closes. Some countries also extend prefilled reporting to the annual VAT summary if one exists (e.g. Italy’s annual return, Portugal’s planned annual SAF-T based return). The goal is to have the draft ready in time so that the taxpayer’s job is mainly to verify and submit, rather than to prepare a return from scratch. [asesoriaga…ialopez.es], [asesoriaga…ialopez.es] [sovos.com], [sovos.com] [vatcalc.com] [sovos.com]

Reconciliation: Taxpayer’s Role in Verifying Prefilled Data

• Proactive reconciliation (before submission): Most systems encourage or require taxpayers to cross-check the prefilled figures with their internal books and invoices before finalizing the return. For example, Italy explicitly advises impacted taxpayers to “cross check the data in the pre-filled Annual VAT Return with the data in their management systems and edit the return accordingly before submitting.” Similarly, when Spain expanded the Pre303 draft service, tax advisors recommended that companies verify the data calculated by the tax agency’s Pre303 against their own accounting software output to catch any discrepancies before filing. In Mexico, the introduction of the new prefilled VAT module came with strong guidance for companies to maintain detailed monthly records and perform reconciliations of CFDI invoices vs. their accounting and cash flows prior to filing each return. The Mexican tax authority even built features to show invoice-level details (including cancellations or amendments) in the app, so that taxpayers can identify issues (like a missing payment receipt, or an invoice recorded incorrectly) and correct them before submission. The rationale is that if the taxpayer can correct errors in advance, the filed return will match the authoritative data, avoiding problems down the line. [sovos.com] [asesoriaga…ialopez.es], [asesoriaga…ialopez.es] [ey.com], [ey.com]
• Ability to edit the draft: Crucially, taxpayers can edit or add to the prefilled return in all these systems. The prefilled forms are not “read-only” – they are a starting point. For instance, Mexico’s system explicitly allows editing of the prefilled amounts if the taxpayer identifies needed changes. Italy’s portal allows taxpayers to modify, integrate (add missing info), and then submit the return; Italy even noted that if a taxpayer needed to change something in the annual VAT draft, they could do so and no penalties would apply as long as it was submitted by the deadline. Chile’s system lets taxpayers supplement the prefilled data with any transactions not captured by electronic invoices (e.g. certain imports or adjustments) before confirming the return. In Hungary’s eVAT, small taxpayers can log in and add any missing invoices or correct any tax coding in their transaction list before approving the draft return. This editability is essential because even with comprehensive e-invoicing, there can be legitimate reasons the draft might need tweaks (e.g., timing cut-offs, special adjustments, or simply errors in the source data that the business needs to fix). [ey.com] [sovos.com], [sovos.com] [vatupdate.com] [vatcalc.com]
• Reactive reconciliation (after submission checks): Some tax authorities have implemented or plan automated checks on filed returns versus their own data, prompting taxpayers to explain discrepancies. In Romania, where taxpayers still submit their own returns alongside the prefilled data, the system flags significant differences: any discrepancy of at least 20% (or at least 1,000 RON) between the taxpayer’s figures and the prefilled draft must be explained in an electronic form to the tax administration. This essentially forces a reconciliation after filing – if the taxpayer didn’t align with the prefilled data, they need to justify why (or correct the return). Mexico’s SAT has indicated it will use the new prefilled return system to generate automatic “invitations” or notices if discrepancies are detected between the taxpayer’s reported data and the CFDI data in the system. In other words, if a Mexican taxpayer files a return that doesn’t match the invoices the SAT knows about, they can expect a prompt letter asking for clarification or correction. The aim is to make non-compliance or mistakes visible immediately. Generally, tax authorities assume that if they gave you a correct draft based on your invoices, any deviation means you either have additional data they didn’t see or you’re making an error. This can shift the burden of proof: the taxpayer may need to prove the draft was missing something rather than the tax authority having to prove the taxpayer’s filing is wrong. [vatupdate.com], [vatupdate.com] [ey.com] [sovos.com]
• Degree of enforcement: While proactive reconciliation is encouraged, not every country penalizes mismatches outright. In most cases, if the taxpayer simply adjusts the draft and files their correct figures, that is accepted (though it might trigger a review). But as these systems mature, the expectation is that taxpayer filings will converge with the government’s data. For example, India’s “hard lock” of certain GST data from 2025 means taxpayers cannot arbitrarily change key values – their return will essentially be forced to align with the auto-populated sales figures unless they have amended the source invoices themselves. This is a form of preventive reconciliation: it ensures the final return matches the reported invoices by design. Hungary’s eVAT provides analytics for taxpayers to compare their records with the tax authority’s records, so they can resolve any gaps before submission – if they do so thoroughly, NAV (the tax authority) is “not likely to request further tax information” or audits for that period. In summary, the onus is on taxpayers to get it right, either before filing or immediately after. Failing to reconcile can lead to audits or automated adjustments. Thus, although one benefit of prefilled returns is reduced effort in preparation, companies often must invest effort in reconciling data to ensure the prefilled return is accurate. [sovos.com] [vatcalc.com], [vatcalc.com] [ey.com], [vatupdate.com]
• Maintaining records: A side effect is that businesses need robust processes to track any data that might not be captured by the tax authority. For instance, if an invoice was issued late or a correction was made after the authority’s cutoff date, the taxpayer must ensure it’s included appropriately. Tax advisors recommend daily or frequent downloads of e-invoice data from the authority’s system (as in Mexico) and prompt communication with suppliers about any invoice issues, so that by the time the return draft is generated, the data is complete. In essence, tax compliance and accounting cycles are becoming more synchronized with real-time reporting – taxpayers are expected to keep their electronic records up-to-date continuously, rather than just scramble at month-end to compile a return. [ey.com] [ey.com], [ey.com]

Final Return: Prefilled vs Taxpayer-Submitted

• Taxpayer must confirm/submit: Every country’s system requires the taxpayer to take an action to finalize the return. For example, Argentina’s IVA Simple system produces a prefilled Form 2051, but taxpayers must confirm or modify that information and submit it – only after that does it count as the filed return. In Italy, the tax authority allowed eligible taxpayers to “view and download” the draft annual return, but the taxpayer then had to modify if necessary and formally submit it by the deadline for it to be considered filed. If an Italian taxpayer did nothing, the prefilled return would not automatically go to the authorities – it’s not a deemed filing; the taxpayer would be in violation for failing to file if they took no action. Similarly, the Spanish Pre303 is a “service de ayuda” (help service) – it prepares a draft, but the taxpayer still completes the submission process to lodge their Modelo 303. No jurisdiction currently considers an unaccepted draft as a filed return. [vatupdate.com] [sovos.com], [sovos.com]
• Prefilled draft vs taxpayer changes: In cases where the taxpayer agrees with the prefilled data entirely, filing can be as simple as clicking an approval. The end result is that the taxpayer’s submitted return is identical to the prefilled draft. However, if the taxpayer disagrees or has extra data, they are free to change the return. The numbers on the final return are the taxpayer’s responsibility, whether they match the draft or not. For instance, Hungary’s eVAT lets taxpayers add missing transactions and then “close” the period and submit – the data after their additions is what gets filed. Chile’s taxpayers can input any transactions not captured by the system (e.g. certain self-assessed items) and then file; the tax authority effectively accepts those additions as part of the return. The tax authority does not unilaterally override a taxpayer’s input at the moment of filing. That said, if there is a serious discrepancy, the authority will likely follow up (as discussed under reconciliation), but the filed return remains the taxpayer’s version unless and until corrected via normal audit procedures. [vatcalc.com], [vatcalc.com]
• Legal responsibility: All these systems maintain that the taxpayer is legally responsible for the return’s accuracy, even if much of it was prefilled by the authority. The prefilled data is based on what the taxpayer (or third parties, like customers/suppliers or customs) reported during the period. If the taxpayer notices an error in the prefilled draft and fails to correct it, that error will become theirs once they file. In Romania, for example, despite introducing the prefilled form, officials made it clear that companies “must still prepare and submit their VAT returns by deadlines” – the prefilled system does not eliminate that obligation. In other words, the taxpayer’s duty to file on time and accurately remains; the system just gives them a pre-prepared form to start with. Because of this, most countries allow amendments and even corrections after submission (under the usual procedures) if something was wrong. Italy noted that taxpayers could submit a correction or supplementary return if they found mistakes in the prefilled annual return after filing, just as they would with a normal return. So the standard rules of taxpayer-filed returns (ability to amend, penalize for inaccuracies, etc.) still apply. The prefilled return doesn’t change who owns the declaration – it’s ultimately the taxpayer’s declaration. [vatupdate.com] [sovos.com]
• No automatic finalization (yet): It’s worth noting that none of these countries have implemented a system where if the taxpayer does nothing, the prefilled return is simply accepted by default. Some income tax systems in the world do that (e.g. prefilled personal income tax returns that are deemed accepted if not modified), but for VAT, currently the process requires affirmative filing. There is discussion in the EU about possibly having “silence is consent” approaches for very simple cases in the future, but as of now, failing to file is not mitigated by the existence of a draft. Taxpayers still have to log in and submit the return (even if it’s just to confirm the prefilled values). The “final VAT return” is thus the one the taxpayer submits (which may equal the draft or may include adjustments). The prefilled version is a preliminary draft – albeit one that carries significant weight.

Similarities and Differences in Approaches

• Digital Data Dependency: A universal theme is that prefilled VAT returns are made possible by detailed digital reporting (e-invoices, real-time transaction reports, etc.). Countries with robust e-invoicing (Chile, Italy, Mexico, India, etc.) can offer comprehensive prefilled returns covering most transactions. Others with partial data (France, which only has import data electronically so far) offer only partial pre-population. In essence, the more data the tax authority collects upfront, the more complete the draft return – this is why many recent VAT reforms (like EU’s upcoming changes) pair compulsory e-invoicing with the prospect of prefilled returns. [vatcalc.com], [vatupdate.com] [sovos.com] [vatcalc.com]
• Scope of Taxpayers: Most regimes aim to include all standard VAT taxpayers once mature, but initial rollouts often focus on larger companies or those already in a special reporting regime. For example, Spain started with the large taxpayers in SII, while Hungary differentiated the approach for small vs. large (portal vs. API) but opened it to all sizes. Italy and Portugal held back certain complex sectors from prefill programs at first. Over time, these distinctions tend to blur as systems improve and mandates expand, bringing in more taxpayers (e.g., France will eventually cover all B2B transactions once e-invoicing is mandatory for all companies by 2026). So differences in scope are often a matter of rollout strategy rather than permanent exclusion. [asesoriaga…ialopez.es] [vatcalc.com] [sovos.com]
• Types of Transactions Covered: In most countries, domestic B2B and B2C invoice data form the backbone of the prefilled return. Differences arise in handling of cross-border transactions and special cases. Some, like Chile and Mexico, incorporate purchases (inputs) as well as sales, giving a full picture of VAT due and credit. Others might initially focus on output tax only and leave input claims to the taxpayer (France’s import prefill only addresses VAT due on imports, not any credits). Another difference is whether additional sources (e.g. customs, cash registers, SAF-T) are integrated; Hungary and Romania are notable for pulling multi-source data into one platform. Generally, the trend is toward including all possible sources so that the draft return is as complete as it can be. [vatupdate.com], [ey.com] [sovos.com] [vatcalc.com], [vatupdate.com]
• Frequency and Timing: Monthly VAT returns are the norm for most large businesses globally, and those are prefilled on a monthly basis. Some small businesses file quarterly; where relevant, the authorities generate quarterly drafts. No country is doing anything unusual like prefilled weekly returns – they stick to the statutory filing periods. One subtle difference is how quickly the draft is made available. In some systems, the draft might appear immediately after the period ends or even continuously update (Hungary’s live portal, Spain’s real-time Pre303 calculation). In others, there may be a slight delay or a set release date (Italy’s annual return was released mid-February for all, regardless of when the taxpayer normally would prepare it). But in all cases, the goal is to have it out before the filing deadline with enough time for the taxpayer to review. [vatcalc.com], [asesoriaga…ialopez.es] [sovos.com]
• Reconciliation Practices: All countries require the taxpayer to ensure accuracy, but enforcement tactics differ. Proactive reconciliation is universally advised – it’s essentially a best practice now for VAT compliance to compare tax authority data to internal records regularly. Reactive measures – like automated discrepancy alerts or required explanations – exist in some regimes (Romania’s 20% rule, Mexico’s planned notices) and not (yet) in others. This reflects a difference in compliance culture: some authorities immediately leverage the prefilled return as an audit tool, while others introduce it first as a convenience and may add enforcement later. Nonetheless, the direction is toward using these systems to close the gap; expect more countries to adopt automatic flags for mismatches as the systems bed in. A notable difference is penalty and tolerance thresholds: Romania set a 20%/1000 RON threshold for differences before requiring an explanation; other countries haven’t codified a threshold, but any large inconsistency would likely trigger scrutiny informally. India’s approach of locking data is another way to enforce reconciliation by preventing discrepancies altogether – a path some advanced systems might follow. [ey.com], [asesoriaga…ialopez.es] [vatupdate.com], [ey.com] [vatupdate.com] [sovos.com]
• Final Return Responsibility: In all jurisdictions, the taxpayer’s submitted return is final, so there’s uniformity on that point. No country so far has deviated to make the prefilled draft automatically binding. The difference is more in taxpayer experience: in some places the prefilled return essentially becomes the return (if no changes are needed) with one click, whereas in others the taxpayer might effectively re-enter the same numbers in their own software to file. For example, early on, some Spanish filers treated the Pre303 as a reference and then manually filed their return in their usual way if they trusted it. But increasingly, integration is improving so that the acceptance is seamless. Thus, the final vs draft question has the same answer everywhere – the taxpayer’s confirmation is key – but the ease of confirming versus overriding may differ. In Hungary, a large company might never even look at a “form” – they’ll reconcile via API and the final submission is just their data feed aligning with the authority’s records. In contrast, a small Greek business might download a draft, compare to their books, and then fill in the official form accordingly. The workflow differs, but legally the outcome is the same. [vatcalc.com], [vatcalc.com]
• Mandatory vs Voluntary Use: A difference worth noting is how quickly authorities make using the prefilled system compulsory. Argentina is making IVA Simple mandatory within a few months of launch for everyone. Hungary and Italy have kept it voluntary initially. The UK (not mentioned above since it doesn’t have a true prefilled VAT return yet) has taken a more indirect approach with Making Tax Digital, requiring digital links but not giving a government-prepared return. So, strategies vary from “we prepare it, you must use it” to “we prepare it, use it if you like.” Over time, if the prefilled returns prove accurate and convenient, it’s likely most countries will make them the default filing method. [vatupdate.com] [vatcalc.com], [sovos.com]