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EU structured e-invoices mandated 2028 intra-community supplies

2028 taxpayers must be able to issue and receive e-invoices within 2 days for Intra-community supplies – VAT in the Digital Age

From 1 January 2028, e-invoices for supplies of goods or services across EU borders (Intra-community Supplies (ICS)) must be issued.  The current maximum issuance requirements of 45 days post taxable event is being shortened to just two days.

This is part of the Digital Reporting Requirements reforms pillar of the EU VAT in the Digital Age package

The EU VAT Directive will be amended accordingly to enable this:

  • Paper invoices will no longer hold equal legal status as e-invoiced from 2028
  • Whilst e-invoicing is not being mandated for domestic supplies – this remains an option of member states – the requirement for states to seek powers from the European Commission to impose e-invoicing will be withdrawn from 2024

Requirements of structured e-invoices

From 2028, paper and basic PDF invoice will not be acceptable as VAT invoices. Instead, structured formats such as XML; UBL; PDF/A3 etc will be required. The EU has already clarified the it will extend with new informational requirements. E-invoices may be issued by taxpayers or their appointed agents. However, there will be no new pre-clearance models (such as Italy and Poland permitted from 2025). Member States shall allow for the issuance of electronic invoices which comply with the European standard on electronic invoicing and the list of its syntaxes pursuant to Directive 2014/55/EU of the European Parliament and of the Council.

The additional data is required:

  • in the case of a corrective invoice, the sequential number which identifies the corrected invoice, as referred to in point (2);
  • the IBAN number of the supplier’s bank account to which the payment for the invoice will be credited. If the IBAN number is not available, any other identifier which unambiguously identifies the bank account to which the invoice will be credited;
  • The date on which the payment of the supply of goods or services is due or, where partial payments are agreed, the date and amount of each payment.

VATCalc transaction determination to structured e-invoice

Our VAT engine, VAT Calculator, is able to determine VAT in real-time, and produce e-invoices to most standards, including PEPPOL or local variations. If you would like to learn more about effortless international determination and electronic invoicing, please contact us.

EU VAT in the Digital Age reforms

EU VAT in the Digital Age
3 reforms to improve efficiency of VAT for all and reduce fraud
1. Single VAT registration in the EU; extension of OSS to B2C own stock movements 2025 (?): Following the 1 July 2021 introduction of the One Stop-Shop (OSS), extended to cover movement of own stocks prior to cross-border B2C to reduce the foreign, non-resident VAT registrations & returns. Plus to movements of own stock with ending of 'call-off' stock burden
More details on Single VAT Registration in the EU
Marketplaces deemed supplier for EU sellers
EU IOSS mandated for marketplaces
EU tackles misuse of IOSS numbers
Quick fixes to existing e-commerce VAT rules
Call-off stock VAT simplification ends
Harmonisation of B2B Reverse Charge rules
2. Digital Reporting Requirements; e-invoicing 2030 (?): Mandatory digital reporting of intra-community transactions; obligation to be able to issue and receive intra-community e-invoices; member states free to impose own e-invoicing or real-time reporting but most conform to EU e-invoice standard EN 16931
Read more about EU Digital Reporting Requirements (DRR)
E-invoices mandated intra-community supplies 2028
EC Sales lists replaced by Digital Reporting Requirements
2014 EU legal permissions for e-invoicing lifted
3. VAT treatment of the platform economy 2026 (?): Travel & accommodation sharing platforms to become deemed supplier / liable to users' VAT. New definitions of the roles of providers, users and platforms to avoid double and no-taxation
Read more - Travel & accommodation platforms deemed suppliers for EU VAT

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