Italy SDI e-invoice update

The Italian tax office has provided further guidance on the 1 January 2019 extension of the Sistema di
Interscambio (SdI) e-invoice reporting to B2C and B2B transactions. This new obligation will require all resident businesses to submit compliant e-invoices to the government’s SdI platform for automatic approval and forwarding onto customers.
The following clarifications were provided:
   » Resident businesses must submit to the SdI platofrm e-invoices for supplies to non-resident businesses. They will not need to include the ‘recipient code’, instead marking zero’s as for B2C invoices. The nonresident customer will be able to retrieve their approved PDF purchase invoices from the SdI platform, or the vendor can provide them. Although the latter would not guarantee a compliant purchase invoice for input VAT deduction.
   » The free government e-invoice storage facility will be effective for 15 years
   » Purchase e-invoices received after the month end, but dated in the prior month, may be deducted in the prior month up until 15th of the month received (the day before the prior month VAT return submission deadline)
   » There is no requirement to give e-invoices unique numbers aside from their regular VAT invoice numbers
   » For domestic reverse charge invoices with the N6 code, the purchaser will use the approved SdI invoice, but will also create a self-invoice. This may (but not mandatory) be submitted to SdI.
   » The Italian Data Protection Authority has raised EU General Data Protection Regulation concerns, and requested a delay in the SdI 2019 modifications.

Esterometro replacing the Spesometro Jan 2019 EU

On 1 January 2019, Italy will withdraw the requirement for resident and non-resident Italian tax payers to complete the Spesometro quarterly / bi-annual sales and purchase invoice listing. This is part of the extension of SdI live invoice reporting to all B2B and B2C transactions. The Spesometro will be replaced by a new monthly filing, the Esterometro, to report transactions outside the scope of the SdI live invoice submissions.
   » Key requirements of the Esterometro are:
   » Monthly filing by resident taxpayers only
   » Listing of sales and purchases to or from non-resident customers and suppliers, including:
   » Domestic supplies;
   » IC acquisitions;
   » Exports or imports without customs declarations; and
   » Purchases of services from non-residents.
   » Transactional data will include: VAT number of Italian supplier/customer; Date; Invoice number; Tax base; VAT due; exemptions
   » Due the last day of the month following the month the invoice was raised

The following invoices may be excluded:
   » Any sales invoices reported through SdI. The non-resident is still entitled to a paper/PDF invoice from the Italian supplier since SdI will not issue it.
   » Imports or exports where a customs document was raised since this will be automatically reported to the tax authorities
   » Non-residents are not required to complete the Esterometro, including for domestic supplies.

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