E‑invoicing and E‑reporting Requirements Webinar (feat. PwC): Continuing the Conversation

Recently, Comarch and PwC hosted a webinar on navigating the new requirements in e-invoicing and e-reporting. The event was filled with great insights and tips from industry experts, including Ellen Cortvriend (Partner - Leader PwC Center of Excellence on e-invoicing and e-reporting), Rafał Trojanowski (Analyst and e-Invoicing Expert at Comarch), and Katya Kancheva (Business Solution Manager at Comarch).

Combining their respective knowledge, our professionals covered the most important e-invoicing and e-reporting issues, such as connecting compliance to the bigger picture, the EU’s VAT in the Digital Age (ViDA), and the challenges of the implementation process.

During this very insightful panel, our audience asked many relevant and interesting questions. Since our experts couldn’t answer them all, we wanted to make it up to you and continue the conversation in the form of this article. Read on to learn even more about new e-invoicing and e-reporting requirements. And, if you haven’t had the chance to catch our webinar when it first aired, you can watch it on-demand.

Q: Does issuing e-invoices for B2C in Hong Kong require consent? The law says consent is only necessary for non-government e-invoices without specifying B2B and B2C regulations.

Yes, issuing e-invoices for B2C in Hong Kong requires consent. According to s15 of HK's Electronic Transaction Ordinance: 15. Consent is required for sections 5, 5A, and 7 to apply to transactions between persons who are not government entities. If an Ordinance requires information to be given by one person to another, and neither person is or is acting on behalf of a government entity, section 5 applies only if the person to whom the information is to be given consents to it being shown in the form of an electronic record.

Q: A couple of questions regarding regulations in Poland: According to Polish law, is there an obligation to retrieve XML from KSEF? Can companies still send PDFs to their business partners? Should reporting include both B2G and B2B invoices? Which platform should be used for B2G invoices – KSeF or PEF? Do we have some technical documentation about QR codes in Poland?

If you are obliged to issue invoices by KSeF, the only possible format is XML (FA(2) structure). After validating such an invoice by KSeF and assigning a KSeF ID number, the buyer can download the invoice from the platform. However, nothing stands in the way of sending the PDF to your contractor after verification of the invoice by KSeF. This will be a prevalent solution for transactions with contractors who do not have access to KSeF (outside Poland). However, it will only be a visualization of the invoice. KSeF will archive invoices for 10 years, but we recommend archiving invoices on your own.

Implementing KSeF will affect the existing system of handling electronic invoicing in public procurement using PEF. The proposed solutions will ensure the interoperability of these two systems. Invoices issued in PEF, after positive validation, should obtain a KSeF ID/UPO number. The PEF e-invoice standard, required by law, would remain in circulation between the issuer and recipient of the e-invoice in B2G transactions. PEF users will be able to use the services provided by KSeF, i.e., semantic validation of e-invoices, storage and access to e-invoices in the system, and verification of the correctness of e-invoices. At the same time, the tax administration will have access to all e-invoices, regardless of whether they were issued according to the PEF standard or the KSeF standard.

Regarding the regulation of QR codes, at the moment, we have a Draft Regulation by the Minister of Finance of February 22, 2023, on the use of the National e-Invoice System (§ 7). Details should be expected with the update of the technical documentation.

Q: With the European VIDA initiative, do you expect the e-reporting model to be deployed?

The reporting mandate will affect intracommunity transactions, but VIDA will likely loosen the EU requirements, which are currently in force, whenever an e-invoicing mandate is introduced. Countries might choose to use the EU technical framework for national mandates – it is not yet clear if it will only be e-reporting or e-Invoicing mandates.

Q: What are “summary invoices”?

Based on Article 223 of the VAT Directive, a summary invoice is an invoice that details several separate supplies of goods or services provided that the VAT on these transactions becomes chargeable during the same calendar month (exceptions are possible where these can even go beyond one month). From now on, invoices need to be issued per transaction. However, there is much pushback on the fact that this option will be abolished according to the proposal. This has a huge business impact.

Q: Regarding e-reporting in France, is there one report combining inbound and outbound invoices, or are there two separate reports? What are the options here?

There are several report types (B2B cross-border transactions, B2C transactions, payment data, usually affecting outbound invoices. However, in specific cases, there are also inbound invoices (foreign invoices). There are different deadlines for submitting the reports, depending on the type of report as well as the chosen tax regime.

Q: Is there any blockchain tech being deployed in Belgium and Poland for e-invoicing?

First of all, no blockchain technology is being deployed in Belgium and Poland for e-invoicing.
Second, the difference between the mentioned models is that one is a real-time reporting system, where the data is only being reported (left side), and the other model is a classic clearance model with the distribution on the taxpayer’s side, where the invoice can only be sent out once it got cleared by the tax authorities.

Q: How do you connect your ERP invoice number to the KSEF invoice number?

In general, the invoice number used up until now and the KSEF ID are different numbers, which do not need to be matched, as the platform assigns the KSEF ID and can be retrieved per each cleared invoice.

About Comarch e-Invoicing

Need help with new e-invoicing and e-reporting requirements? Check out Comarch e-Invoicing System – a  powerful and comprehensive product that both streamlines and automates all of your AP/AR invoicing processes to enable a secure and highly efficient document exchange with all of your business partners and clients. Our software can help you optimize the payment process, reduce operational costs, strengthen your business relationships, and ensure full compliance with legal regulations. Click here to ask our experts for details.