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Study on on the evaluation ofthe invoicing rules ofDirective 2006/112/ECFinal ReportVolume 2 – AnnexesJanuary 2019

EUROPEAN COMMISSIONDirectorate General for Taxation and Customs UnionDirectorate C – Indirect Taxation and Tax AdministrationUnit C.1 – Value Added TaxE-mail: TAXUD-UNIT-C1@ec.europa.euEuropean CommissionB-1049 Brussels

Europe Direct is a service to help you find answersto your questions about the European Union.Freephone number (*):00 800 6 7 8 9 10 11(*)The information given is free, as are most calls (though some operators, phoneboxes or hotels may charge you).LEGAL NOTICEThe information and views set out in this report are those of the author(s) and do not necessarily reflect theofficial opinion of the Commission. The Commission does not guarantee the accuracy of the data included inthis study. Neither the Commission nor any person acting on the Commission’s behalf may be held responsiblefor the use which may be made of the information contained therein.More information on the European Union is available on the Internet (http://www.europa.eu).Luxembourg: Publications Office of the European Union, 2019ISBN 978-92-79-99231-5doi: 10.2778/09368 European Union, 2019Reproduction is authorised provided the source is acknowledged.

Study on on the evaluation of the invoicing rules of Directive 2006/112/ECTable of ContentsANNEX A. TARGETED CONSULTATIONS . 6ANNEX B. PUBLIC CONSULTATION - SYNOPSIS REPORT . 19ANNEX C. CATEGORISATION OF NATIONAL LEGAL FRAMEWORKS . 46ANNEX D. OVERVIEW OF ADDITIONAL REQUIREMENTS . 53ANNEX E. LIST OF REFERENCES . 57ANNEX F. EVALUATION MATRIX . 604

Study on on the evaluation of the invoicing rules of Directive 2006/112/ECAcronyms and AbbreviationsAESAdvanced Electronic SignatureBCATBusiness Controls that create a reliable Audit TrailBnBillionBSBusiness CustomerB2GBusiness-to-GovernmentCACash AccountingCENEuropean Committee for StandardizationDG TAXUDDirectorate General for Taxation and Customs Unione- electronic ECEuropean CommissionECBEuropean Central BankEDIElectronic Data InterchangeEOEconomic OperatorERPEnterprise Resource PlanningEUEuropean UnionEUREuroICTInformation and Communications TechnologyITInformation TechnologyI&AIntegrity and AuthenticityMnMillionMNCMultinational CorporationMSMember StateNGONon-governmental OrganisationOOthersOECDOrganisation for Economic Co-operation and DevelopmentOLSOrdinary Least SquaresPCPublic ConsultationPDFPortable Document FormatPIPrivate IndividualsPPPublic ProcurementQESQualified Electronic SignatureSAF-TStandard Audit File for TaxSIDSecond Invoicing Directive (Directive 2010/45/EU)SMESmall and Medium EnterpriseSPService ProviderTATax AuthorityTCTargeted ConsultationVATValue Added TaxVIESVAT Information Exchange SystemVPVAT PractitionerXMLExtensible Markup Language5

Study on on the evaluation of the invoicing rules of Directive 2006/112/ECANNEX A. TARGETED CONSULTATIONSA.1 OverviewThe Study relied on various streams of targeted consultations.The targeted consultations were designed to elict information and opinions from a vastrange of private and public stakeholders. They encompass: (i) a number offamiliarization interviews (describe in Section D.2); (ii) fieldwork in seven MemberStates, covering tax authorities, economic operators, business federations, VATpractitioners, and providers of e-invoicing services (D.3); (iii) an e-mail survey of taxauthorities in the non-fieldwork Member States (D.4); and (iv) an e.mail survey of VATpractitioners (D.5).In total, 202 stakeholders participated to the targeted consultation. Economicoperators represent the most important category with 83 stakeholders, followed bybusiness federations and tax authorities. Figure 1 provides an overview of thedistribution. Obviously, the bulk of stakeholers originate from the fieldwork MemberStates; however, stakeholders from 26 Member States participated in theconsultations, thus ensuring a very comprehensive coverage. Figure 2 shows thegeographical distribution. From a geographifcal perspective, the consultations alsocovered 13 EU-level organisations, and 7 multi-national companies.Figure 1 – Breakdown stakeholders interviewed by stakeholder categoryOther3%TA14%VP24%BF9%SP9%EO41%VP: VAT Practitioners; SP: Service Providers; TA: Tax Authorities; EO: Economic Operators; BF: BusinessFederations.Figure 2 – Breakdown of stakeholders interviewed by Member %PL9%NL7%* Other: MS with less than 5 participating stakeholders are summarised as ‘other’. These are: AT,BE, BG, CZ, DK, EE, IE, EL, HR, CY, LV, LT, LU, HU, SI, SK, FI, SE; MNC: MultiNational Companies.6

Study on on the evaluation of the invoicing rules of Directive 2006/112/ECA.2 Familiarisation interviewsThe familiarisation interviews were conducted during the inception phase(between December 2017 and January 2018), to gather a better understanding of theoverall functioning of the Directive, and elicit comments and opinions from the key EUlevel stakeholders and experts regarding the legal changes introduced and their possibleeffects as well as implementation issues. A total of 14 stakeholders were interviewedface-to-face or via telephone, based on semi-structured checklists (see Table 1).The interviews conducted involved different categories of stakeholders, namely eightVAT practitioners or federations thereof, two EU business federations, two serviceproviders or federations thereof, and two other stakeholders. In accordance with theAssignment’s proposal, the key targets for the familiarisation interviews were themembers of the various EU-level expert groups, such as the EU VAT Forum and the VATExpert Group.The Consultant also took part in two focus group discussions, namely: (i) one withsome members of the European Multi-Stakeholder Forum on e-Invoicing, organised withthe support of DG GROW at the margins of the Forum’s official meeting held on 9December 2017 in Brussels; and (ii) one organised within the framework ofBusinessEurope’s VAT Group meeting, with the participation of eight national businessassociations and six multinational corporations. Finally, the Consultant participated in atwo-day working meeting in Stockholm with the legal compliance team of Trustweaver,one of the leading e-invoicing services providers in the EU.Table 1 – List of interviewees in familiarisation interviews#NameAffiliationPositionTypeDateMod1Chas RoyChowdhuryAssociation of CharteredCertified AccountantsHead of Taxation Professional 5/12/2017FDirector of theEconomic and FiscalPolicy CommitteeBF14/12/2017FeGOV ProjectManagerOther9/12/2017FSecretary GeneralSP15/12/2017FManaging KristianKoktvedgaard2VAT Working GroupChairBusinessEuropePieter Baert3ThierryCharonRoxaneLauwereinsStephen Dale4AlexandreSavaryAdviserEuropean VAT ClubInternational VATAssociationEuropean Union of Craftsand Small and Mediumsized EnterprisesBelgian Federal PublicService - Policy andSupportEuropean E-InvoicingService ProvidersAssociationEuropean Federation ofAccountants andAuditors for Small andMedium-sizedEnterprises5GerhardHuemer6Serge Libert7Charles Bryant8PaulThompson9FabiolaAnnacondiaIBFDAndrea CacciaChairman of CEN/TC 434- Technical Committeeon Electronic Invoicing10EU relations and legalresponsibilityIndirect Tax PracticeGroupChairmanMemberPrincipal VATSpecialistChairman of CEN/TC434 - TechnicalCommittee onElectronic Invoicing7

Study on on the evaluation of the invoicing rules of Directive liationPositionTypeDateModIndependent ExpertTax P11-12/01/2018FHead of Unit G412DG ESTATIuliana LupuPaul Gisby13Ralph KorfAccountancy EuropeErnesto Gatto14Statistical Officer ICT Usage /Enterprise surveyManager (VAT TaskForce Member)Chairman VAT TaskForceMemberrepresentative atAccountancy EuropeChristiaan vander ValkPresidentStina averLegal CounselLegal CounselAnna NordenGeneral CounselNote: F Face-to-Face Interview; P Teleconference; W Written consultation.A.3 Targeted consultation in fieldwork Member StatesThe fieldwork targeted consultation has been carried out in seven selectedMember States: France, Germany, Italy, the Netherlands, Portugal, Poland, andRomania. The sample of Member States was selected on the basis of four key criteria.On the one hand, to maximise the sample representativeness, an appropriate coverageof different European regions, characterised by different economic structures anddevelopment, business behaviours as well as regulatory frameworks (geographicalbalance), as well as of Member States with a different dimension (size balance) weretaken into consideration. On the other hand, in order to focus on countries moreinformative on the results achieved by the Directive and the remaining issues, countrieswhere national VAT legislation was significantly amended following the transposition ofthe Directive (Directive impact) and with different levels of burdensomeness ofnational requirements (invoicing burdensomeness), as evidenced by the legalmapping, were given a preference. Table 2 provides an overview of the seven selectedcountries and the described criteria.Table 2 – Overview of fieldwork Member rective impactInvoicee-invoicing mplification Western on AdditionalelementsProhibition to usescanned PDFinvoices for VATdeductionsrecently removedStoragerequirements fore-invoicesintroducedBCAT with writtenprocedure (forlarge firms)Complex archivingrequirements inplaceCash accountingwithoutpostponement ofVAT deduction8

Study on on the evaluation of the invoicing rules of Directive thernEasternNorthwestern Complex archivingrequirements inplace Mandatory B2Gand incomingmandatory B2B Additional ereportingrequirementsimposed Requirement tohave e-invoicingsoftware certifiedby tax authority Additional ereportingrequirementsimposed Cash accountingscheme, withpostponement ofVAT deduction forcustomers Cash accountingscheme, withpostponement ofVAT deduction forcustomers None* For NL, a major simplification occurred in connection to the Directive approval process.The interview programme in each of the seven Member States was targeted at: (i) theTax Authority (TA); (ii) Business Federations, also including SME federations (BF);(iii) Economic Operators of different sizes and active in a variety of sectors (EO); (iv)e-invoicing and e-archiving Services Providers (SP); and (v) VAT Practitioners andtax advisors (VP). The aim was set at 12 interviews per Member State, which was metin all and greatly surpassed in some of the cases, with a total of 152 interviews. Figure3 presents the share of interviews by the five stakeholder types. Figure 4 presents theshare of interviews per Member State.Figure 3 – Breakdown of interviewees by stakeholder typeVP16%Other2%TA6%BF11%SP10%EO55%Note: ‘Other’ includes a multi-stakeholder forum to discuss e-invoicing issues, an e-invoicing international expert, and aresearch institute. VP: VAT Practitioners; SP: Service Providers; TA: Tax Authorities; EO: Economic Operators;BF: Business Federations.9

Study on on the evaluation of the invoicing rules of Directive 2006/112/ECFigure 4 – Breakdown of interviews by Member ROOtherEUMNCThe responsiveness of economic operators varied across size class. Large companiesshowed a fair interest in contributing to the evaluation, but SMEs were more difficult toreach. In order to ensure a sufficient coverage of all size classes, the Consultant elicitedthe support of various business federations. Eventually, 83 economic operators tookpart in the consultation and SMEs represent a sizable share of about 42%.Moreover, an involvement of companies from a variety of business sectors wasachieved, with a limited focus on sole traders, who mostly deal with B2C operationswhich may no entail the issuance of a VAT invoice. Figure 5 shows the distribution amongsize class and business sector.Figure 5 – Breakdown of interviewed economic operators by size class (left)and business sector (right)9%Multinationals42%49%Domestic de37%OtherFor each of the five types of stakeholders interviewed, a tailored questionnairewas prepared, as approved by the Client. For instance, while the questionnaire forbusiness federations was mainly aimed at discussing overarching invoicing themes andissues affecting the majority of companies, the questionnaire for economic operatorsspecifically focused on the invoicing practices and regimes in use and their related costs.Each questionnaire was further checked and possibly tailored for each interviewee, tofocus on their main interests and areas of expertise, as well as to account for thedifferent legal changes introduced in the relevant national legislation. For example,when interviewing stakeholders in France, the questions on the cash accounting regimefor micro-enterprises were removed, since French legislation does not envisage it.10

Study on on the evaluation of the invoicing rules of Directive 2006/112/ECTypically, the customised questionnaire was sent to the interviewee a few daysin advance, in order to provide a preliminary idea of the kind of information theConsultant aimed at collecting. This was especially the case with economic operators,since the quantitative information requested usually required a preliminary effort by theinterviewee, which, especially in structured companies, had to interact with the variousinternal departments or personnel involved in the invoicing process. For this reason, acompact version of the questionnaire for economic operators was created, retaining onlyquantitative questions, which was shared with the companies to allow its pre-filling.After receipt of the pre-filled questionnaire, the Consultant then recontacted theeconomic operators – via email or over the phone – to clarify any outstanding issuesand to discuss the remaining, mostly qualitative, parts of the questionnaire. Asmentioned above, a number of economic operators were not available for an interviewand preferred to provide contributions in writing. While this modality would have hardlysuited the other types of stakeholders, given the need to ask qualitative and in-depthquestion, it proved effective in retrieving the data on the number of invoices and theassociated costs needed to populate the Standard Cost Model.The series of on-the-ground missions allowed to conduct the majority of interviews(49%) in person through face-to-face meetings. A number of interviews took alsoplace through teleconferences (20%) or in writing via an email interaction (31%).Table 3 – Interviewees in the targeted consultation in fieldwork Member States#NameAffiliationGareth O'HalloranGareth O'HalloranCoca Cola 6/2018PEO22/06/2018WTax and InvoicingAdvisorBF09/05/2018PTax AdvisorVP17/05/2018FTax AdvisorVP17/05/2018FHead of Unit - Taxand 05/2018FPositionMultinational corporations12Region TaxManagerRegion TaxManagerEU & InternationalTax ManagerInhouse Solutionsfor Tax (IST) Global VAT/GSTGlobal IndirectTax SolutionManagerEuropean SeniorManager EUIndirect Tax andTax TechnologyRegion TaxManagerCoca Cola HBC Italy3Luc DhontProcter and Gamble4Karl-HeinzHaydlGeneral Electric5Eric MagnussonVolvo6Alfredo EspadaMartinezFord7Gareth O'HalloranCoca Cola HBCRomaniaGermany8Dirk Pick9Carsten tte Selter13BrigitteNeugebauerBundesverband derDeutschenVolksbanken undRaiffeisenbanken e.V.- BVRAWBSteuerberatungsgesellschaft mbHnesemann &grambeckZentralverband desDeutschenHandwerks undUnternehmerverbandDeutsches HandwerkBundesverband derDeutschen Industriee.V.Deutscher IndustrieundHandelskammertagAdvisor - Tax andFinancialManagementHead of Unit VAT andConstitutional Law11

Study on on the evaluation of the invoicing rules of Directive eMod14Inga BethkeBundessteuerberaterkammer/GermanFederal Chamber ofTax AdvisersHead of Unit - TaxLaw and InvoicingVP30/05/2018F15Jens KeeseVolkwsagenTax inisteriumder FinanzenSenior OfficerTA31/05/2018F17Marcus LaubeCrossinxCEOSP04/06/2018PEgovision GmbHManaging O15/06/2018WTax ConsultantEO19/06/2018PTax rankImmendorfHelmutStolzenhoffBerliner utscher Banken(BDB)20Kolja Dette21EstherDallmann22Sabine Weber23Derk BienenBKP DevelopmentManaging DirectorEO21/06/2018W24EmmanuelBaudeletP&B GbRPartnerEO21/06/2018W25ChristophHirschOpel GmbHHead of TaxPlanning andControversyManagementEO25/06/2018P26Hellfried KujusManaging DirectorEO25/06/2018P27Angelika AnnaKirchenEO27/06/2018P28Philip HolzEO28/06/2018P29Marie-ChristinReichAdvisor for taxesand financesBF29/06/2018P30Ivo MuchinskiHead of 6/06/2018FHoku - Holz undKunststoff GmbHBoehringer IngelheimCorporate CenterGmbHLausitz EnergieBergbau AGDerMittelstandsverbund– ZGV e.V.FeRD (Forum forelectronic invoicingGermany)Original UnverpacktHead of TaxCompliance andIndirect TaxProcess ctor ofInnovativeProductsDirector of FiscalPolicies32Gianni MusuI.T.RE DGM srl33Enrico Valeria PenazziValeria rmineRuopoloConsorzio 0/07/2018PTA21/06/2018FEO22/06/2018F363738Ernesto GattoConsiglio Nazionaledei dottoricommercialisti e degliesperti contabili39Milena PasenteMinistero Econonomiae Finanze40MassimoBattistellaTelecom ItaliaDirector rvices Manager12

Study on on the evaluation of the invoicing rules of Directive teModEO22/06/2018F41Rosario FarinaENELAccountingManager42Uberto PignattiMoranoUberto PignattiMoranoSelf-employedEO26/06/2018W43Roberto MorottiRoberto oEO27/06/2018W29/06/2018P45Andrea CacciaLesepidado SrlANORCLuigi tControllerMember of theBoardVPDirectorStudio ParadisiPartnerVP03/07/2018PIfin SistemiGeneral ManagerSP03/07/2018PElena LauritanoArchiviumGeneral ManagerSP03/07/2018F49Claudio BisiFaber SystemCFOSP03/07/2018W50Not DisclosedInfocertNot i Pieri andPartnersOwnerVP03/07/2018P52Enzo FanìLAPAM53MaurizioCarravettaSiemens54Mauro FavaEdizione55Claudia CittonAltana56Not Disclosed4748Director of FiscalAdviceVAT and IndirectTaxes ManagerHead of Fiscal andInsurance untantEO12/07/2018WAccarino CostruzioniNot DisclosedEO12/07/2018WEO12/

ANNEX B. PUBLIC CONSULTATION - SYNOPSIS REPORT . 19 ANNEX C. CATEGORISATION OF NATIONAL LEGAL FRAMEWORKS . 46 ANNEX D. OVERVIEW OF ADDITIONAL REQUIREMENTS. 53 ANNEX E. LIST OF REFERENCES . 57 ANNEX F. EVALUATION MATRIX . 60. Study on on the evaluation of the invoicing rules of Directive 2006/112/EC 5 Acronyms and Abbreviations AES Advanced Electronic Signature BCAT Business .

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