The suggested amendments below are limited to the e-invoicing and digital reporting requirements.
These amendment suggestions will be reviewed by the European Commission.
Setting a minimum threshold for being qualified as a taxable person for VAT purposes, i.e. taxable person for VAT purposes means any natural or legal person who independently carries out any economic activity with an annual turnover of more than EUR 30 000 or the equivalent in the national currency.
A longer transition period for smaller companies will ease the burden on SMEs.
The deadlines for the entry into force of the main dates are delayed by 24 months, i.e., e-invoicing implementation is to be pushed until 2026 / 2028, and the DRR set to commence in 2028 would be pushed until 2030.
The following amendments are suggested regarding electronic invoicing:
The deadline for the issuance of an invoice for cross-border transactions is set at (5) working days after the chargeable event has taken place. The deadline of 2 working days is difficult for SMEs to meet.
Member States are allowed to authorize other means than e-invoicing for domestic supplies for transactions below a threshold of EUR
The issuance of e-invoices by the supplier and its transmission to the buyer is conditional on prior authorization or verification by the tax administration.
The use of European e-invoicing standard EN16931 for the transmission of invoice data at a national level is optional for Member States.
The requirement to state IBAN in case of bank account payment is removed.
The new definition of electronic invoice comes into force in 2028.
Non-established invoice recipients in a Member State mandating the e-invoice issuance may require the invoice issuer to send the invoice in paper or any other format during the transitional period.
The following amendments are suggested regarding the Digital Reporting Requirements:
The deadline for the digital transaction report by the taxable person, or a third party on behalf of the taxable person is extended to (5) / (7) / (10) / (12) days after the posting date in the taxable person’s accounting books.
Member States may introduce the EU reporting requirements first and only if the expected objectives are achieved, the system should be extended to domestic transactions as well.
Member States may allow local digital reporting requirements for purchases based on non-EU standards.