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Is Europe in the ban of the VAT Directive simplification on e-Invoicing?

[2014]Update on the adoption of the proposed changes of the VAT Directive:

On 16 April 2014 the European Commission published the Directive 2014/55/EU which states that Member States will have to implement e-invoicing at the latest by 27 November 2018


End Update

[2011]Update on the adoption of the proposed changes of the VAT Directive:

On 2 December 2010 the European Commission published their communication “Reaping the benefits of electronic invoicing for Europe” (COM(2010) 712 final) and their decision “Setting up the European Multi-Stakeholder Forum on Electronic Invoicing (e-invoicing)”(C(2010) 8467 final).

The Communication identifies a set of actions to support the uptake of e-invoicing by ensuring legal certainty and promoting the development of interoperable e-invoicing solutions based on a common standard, paying particular attention to the needs of SMEs. The Communication also invites the Member States to take action and promote e-invoicing at national level. All actions aim at making e-invoicing the predominant method of invoicing by 2020.

2010/C 326/0 of 2 November 2010

COM(2010) 712 final of 2 December 2010

C(2010) 8467 final of 2 December 2010

On 13 July 2010 the Economic and Financial Affairs Council accepted the new revised VAT Directive 2010/45/EU amending the Directive 2006/112/EC on the common system of value added tax as regards the rules on invoicing. Changes issued with the proposal COM/2009/0021 final - CNS 2009/0009 from 28 January 2009 were only for a small part taken over. The most important change proposed with COM/2009/21 on removing the article 233 has been rejected. However the rules for ensuring the authenticity of the origin and integrity of the content are now extended with the use of business controls as the primary way.

Each taxable person shall determine the way to ensure the authenticity of the origin, the integrity of the content and the legibility of the invoice. This may be achieved by any business controls which create a reliable audit trail between an invoice and a supply of goods or services.

Also a proper and clear definition of what is understood with the terms authenticity and integrity are presented.

‘Authenticity of the origin’ means the assurance of the identity of the supplier or the issuer of the invoice.

‘Integrity of the content’ means that the content required according to this Directive has not been altered.

CNS/2009/0009 Procedure File

VAT Directive 2010/45/EU

End Update

The European Commission on 28 January 2009 adopted a proposal to change the VAT Directive 2006/112/EC (from 28 November 2006) with respect to invoicing rules. The main objectives are to reduce burden on business, increase the use of e-Invoicing, support small and medium sized enterprises (SMEs) and help Member States tackle fraud.

The foundation of the proposal is based on “equal treatment of paper and electronic invoices” in a technology neutral way by removing the conditions for an Advanced Electronic Signature (AES) and Electronic Data Interchange (EDI). The reasoning is that e-Invoicing is part of a larger process where every process step contributes to authenticity and integrity of the trade transaction.

Several Member States and Solution Providers believe these guarantees can only be provided by electronically signed e-invoices. Removing the requirement to guarantee the authenticity of origin and integrity of content by means of pre-defined technological solutions, such as EDI and Electronic Signatures, is therefore the most challenging from a political and governmental perspective for the coming years. It requires a “paradigm shift” in thinking about audit management processes and strategies by all parties involved, whether that be Tax Authorities, Solution Providers or Small, Medium-sized and Large Companies.

Since 2006 stakeholders in Europe have been working hard on developing measures and establishing procedures for simplifying, modernising and harmonising the VAT Invoicing Rules. All the reports of experts in the field, opinion statements and position papers issued by Federations, Associations, Member-Based Communities, Government Authorities and Public Administrations indicate that a majority of stakeholders supports the simplification of e-Invoicing by establishing equal treatment of paper and electronic invoices.

The Expert Group on e-Invoicing installed by the European Commission on 31 October 2007, tasked to propose a European e-Invoicing Framework (EEI Framework), has issued their Final Report on November 2009. The recommendations of the Expert Group and the reactions from stakeholders in Europe will be taken into account by the European Commission in developing its further position on e-Invoicing.

See the final report and the consultation document:

See the final report:

The Expert Group on e-Invoicing in their Final Report ascertain that there are two key issues:
- The present European landscape of e-invoicing legislation is disharmonised. The methods set out in Article 233 of Directive 2006/112/EC have been implemented in Member States’ national legislation in widely different ways. This leaves trading parties experiencing difficulties in finding the right degree of clarity and legal certainty to encourage adoption of e-Invoicing.

- Internal business controls did not receive appropriate attention in the current legislative framework and its implementation. This is unfortunate because such controls are essential to all invoicing processes and, for most, whose systems are mature and robustly auditable, can actually provide the necessary assurance and without creating technical and operational complexity.

Based on the principles of equal treatment between paper and electronic invoices, technology neutrality and internal business controls, the Expert Group issued their recommendations. With regard to article 233 they recommend that “No legislative or other requirements should be imposed on electronic invoices above those that exist for paper invoices today”.

They furthermore state that “The Commission’s January 2009 proposal for a new VAT Directive (COM(2009) 21 final), should be adopted by all Member States and transposed into national legislation. In particular the provisions of Articles 232–237 of the current Directive on the Common System of Value Added Tax (2006/112/EC) should be removed so as to shift from technology based requirements to requirements based on equal treatment, technology neutrality and internal business process controls”.

Additionally they state “In the short term, pending the adoption of the new VAT Directive, those Member States who have not yet done so, should be encouraged to implement the option of ‘other means’ as provided for in the current VAT directive (Directive 2006/112/EC) so as to enable the practical implementation of the Expert Group’s Code of Practice”.

Despite the efforts of all those people some stakeholders start raising their concerns on the recommendations of the Expert Group and on the measures announced by the European Commission. The contributions of these stakeholders in normalisation and standardisation committees aimed at crafting meaningful and long-term simplification and harmonisation of e-Invoicing have been intense and fruitful.

Although the European Commission has not yet decided on the final outcome of the Regulatory Requirements for Electronic Invoicing recent announcements of stakeholders are jeopardizing the viability and sustainability of the hard work done and the future position of e-Invoicing.

In my opinion Europe needs an intermediate state to overcome all the discussions and enable all stakeholders to leverage technological, functional and legal innovations in the domain of e-Invoicing, e-Archiving and e-Procurement. In that respect the best European leaders can do now is to reinstate Article 233 in the proposed VAT Directive and add to it as the first option the use of a Business Control and Tax Control Framework as extensively described in the CWA 16047 - CEN / ISSS eInvoicing Compliance Guidelines or CEN / Fiscalis e-Invoicing Good Practice Guidelines.

See first version:

Latest version can be found on:

The consultation on the Final Report of the Expert Group on e-Invoicing will definitely shed some lights on the visions and standpoints of the different parties.

Today [16 March 2010] the European Ministers of Finance apparently decided not to await the outcome of the consultation and during the ECOFIN Meeting adopted a revised version of the VAT Directive containing changes reinstating the article 233 adding to it the option of the Business and Tax Control Process Framework.

Looking at the evolution of Electronic Invoicing in Europe one can conclude a lot has happened since the European Commission started in 2001 with amending the regulatory requirements for Electronic Invoicing in Europe. In general almost all stakeholders called upon to support the principle of equal treatment of paper and e-invoicing on authenticity and integrity.

Let us have a look at the developments that took place in the past years: