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ViDA Analyzed – Part 11: What needs to be reported under ”Digital Reporting Requirements” compared to Art. 226 of the Directive

Comparison between Content of an invoice (mandatory data fields on an invoice) as per art. 226 compared to Article 264 of the EU VAT Directive 2006/112/EC.

Article 264 (as applicable as of Jan 1, 2028)

The data transmitted in accordance with Article 263 shall contain all of the following:
(a)the information referred to in Article 226, points (1) to (4), (6), (8) to (11a), (16), (17) and (18);
(b)in respect of supplies of goods consisting in transfers to another Member State, as referred to in Article 138(2), point (c), the total value of the supply, determined in accordance with Article 76


Content of an invoice as per art. 226 also to be mentioned on DRR

  • (1) the date of issue
  • (2) a sequential number, based on one or more series, which uniquely identifies the invoice;
  • (3) the VAT identification number referred to in Article 214 under which the taxable person supplied the goods or services;
  • (4) the customer’s VAT identification number, as referred to in Article 214, under which the customer received a supply of goods or services in respect of which he is liable for payment of VAT, or received a supply of goods as referred to in Article 138;
  • (6) the quantity and nature of the goods supplied or the extent and nature of the services rendered;
  • (8) the taxable amount per rate or exemption, the unit price exclusive of VAT and any discounts or rebates if they are not included in the unit price;
  • (9) the VAT rate applied;
  • (10) the VAT amount payable, except where a special arrangement is applied under which, in accordance with this Directive, such a detail is excluded;
  • (10a) where the customer receiving a supply issues the invoice instead of the supplier, the mention ‘Selfbilling’;
  • (11) in the case of an exemption, reference to the applicable provision of this Directive, or to the corresponding national provision, or any other reference indicating that the supply of goods or services is exempt;
  • (11a) where the customer is liable for the payment of the VAT, the mention ‘Reverse charge’;
  • (16) in the case of a corrective invoice, the sequential number which identifies the corrected invoice, as referred to in point (2);
  • (17) the IBAN number of the supplier’s bank account to which the payment for the invoice will be credited. If the IBAN number is not available, any other identifier which unambiguously identifies the bank account to which the invoice will be credited;
  • (18) The date on which the payment of the supply of goods or services is due or, where partial payments are agreed, the date and amount of each payment.

Content of an invoice as per art. 226 NOT to be mentioned on DRR

  • (5) the full name and address of the taxable person and of the customer;
  • (7) the date on which the supply of goods or services was made or completed or the date on which the payment on account referred to in points (4) and (5) of Article 220 was made, in so far as that date can be determined and differs from the date of issue of the invoice;
  • (7a) where the VAT becomes chargeable at the time when the payment is received in accordance with Article 66(1), point (b), and the right of deduction arises at the time the deductible tax becomes chargeable, the mention ‘Cash accounting’ where the VAT becomes chargeable at the time when the payment is received in accordance with Article 66(b) and the right of deduction arises at the time the deductible tax becomes chargeable, the mention ‘Cash accounting’;
  • (12) in the case of the supply of a new means of transport made in accordance with the conditions specified in Article 138(1) and (2)(a), the characteristics as identified in point (b) of Article 2(2);
  • (13) where the margin scheme for travel agents is applied, the mention ‘Margin scheme — Travel agents’;
  • (14) where one of the special arrangements applicable to second-hand goods, works of art, collectors’ items and antiques is applied, the mention ‘Margin scheme — Second-hand goods’; ‘Margin scheme — Works of art’ or ‘Margin scheme — Collector’s items and antiques’ respectively;
  • (15) where the person liable for payment of VAT is a tax representative for the purposes of Article 204, the VAT identification number, referred to in Article 214, of that tax representative, together with his full name and address.

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