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Taiwan Clarifies E-Invoice Allowance Note Obligations for Returns and Discounts

Summary

  • Since 1 January 2025, a seller that has issued an electronic invoice must create an electronic allowance note when the parties subsequently agree to a sales return, purchase withdrawal or discount. The allowance note must be issued electronically and transmitted to Taiwan’s Ministry of Finance E-Invoice Platform for retention. [tinyurl.com], [ntbna.gov.tw]
  • The transmission deadline depends on the buyer’s status. Information must be uploaded by the seller within two days from the day following issuance where the buyer is a non-business entity, or within seven days where the buyer is a business entity. Late or inaccurate transmission may result in penalties. [tinyurl.com], [ntbna.gov.tw]
  • Businesses should ensure that the return or discount has been agreed by both parties before transmitting the allowance information. Agreement messages and supporting evidence for transactions concluded through websites, telephone or other electronic channels must be retained for at least five years, requiring coordinated tax, accounting and systems controls. [tinyurl.com]

Article

The National Taxation Bureau of the Northern Area, part of Taiwan’s Ministry of Finance, has clarified the electronic invoicing requirements applying when goods or services are returned, withdrawn or discounted after an electronic invoice has been issued. The announcement, released on 28 July 2026, reiterates obligations that have applied since 1 January 2025. [tinyurl.com]
Where the buyer and seller agree to a sales return, purchase withdrawal or discount, the seller must issue an electronic invoice allowance note using the internet or another electronic method.
The seller must then transmit the allowance-note information to the Ministry’s E-Invoice Platform. The seller or buyer may download the stored record for use as supporting documentation for tax deductions or accounting purposes. [tinyurl.com], [ntbna.gov.tw]
The applicable reporting deadline is determined by the buyer’s status. For transactions with a non-business buyer, the seller must upload the allowance-note information within two days from the day following issuance. Where the buyer is a business entity, the deadline is seven days from the day following issuance. These requirements arise under the information transmission framework established pursuant to Article 32-1(4) of Taiwan’s Value-Added and Non-Value-Added Business Tax Act. [tinyurl.com], [ntbna.gov.tw]
Failure to upload accurate information within the prescribed period may result in a fine ranging from NT$1,500 to NT$15,000 under Article 48-2 of the Business Tax Act. An exemption may be available where the conditions in Article 16-3 of the Standards to Mitigate or Remit Punishment of Tax Misconduct, Violation, and Fraud Cases are met. Any reliance on this relief should be assessed against the specific facts and applicable administrative requirements. [tinyurl.com], [ntbna.gov.tw]
The authority also stresses that an allowance note should only be transmitted after the parties have agreed to the underlying return or discount. Where agreement is reached through a website, telephone or another electronic channel, the agreement message and relevant supporting documents must be retained for at least five years. This requirement is particularly relevant to e-commerce, customer service and automated returns processes. [tinyurl.com]
The temporary guidance period, which ran from 1 January to 30 June 2025 and allowed businesses time to update systems and accounting procedures, has ended. Businesses should therefore review whether credit-note and returns workflows correctly identify the buyer type, capture evidence of agreement, generate the required electronic allowance note, and transmit it within the two-day or seven-day deadline. Controls should also monitor rejected or incomplete platform submissions and preserve a clear audit trail. [tinyurl.com], [ntbna.gov.tw]

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