VAT e-invoicing mandate planning underway – 2025 target – to supplement myDATA transaction reporting for pre-filled VAT returns
Greece’s Ministry of Finance and tax authority (AADE) has confirmed that it is discussing the necessary derogations from the European Commission to vary from the EU VAT Directive and impose VAT e-invoicing obligations on taxpayers. The authorities believe this may come as soon as 2025.
This would support the existing myDATA regime which already requires full reporting of VAT invoices and e-Books to the tax authority’s portal since 2022. This will result in pre-filled VAT returns possibly from 2025.
Transmission of myData via ERP goes live January 2024
The Greek digital My Digital Accounting and Tax Application (“myData”) invoicing and bookkeeping regime is being updated for users reporting via ERP’s. The new requirement from the Greek tax office, AADE for transmission of summary data will switch to live reporting (effectively same day of sales invoice issuance) from 1 January 2024. Taxpayers reporting by other routes (manually, cash registers or portal upload) are unaffected. AADE announced a range of other changes, including using QR Codes from systems for fiscal receipts.
myData sales & purchase invoice and ledger reporting
myData was phased in between 2021 and 2022. It covers: sales & purchase invoices; and key ledgers reporting:
- e-Books or Ledgers: General Ledger; Payroll; Fixed Assets, including amortisation. Cross-border transactions and B2C sales not included in e-Invoices
- e-Invoices: B2B sales and purchase invoices, which accounting coding data. Only sales invoices are shared with AADE which is then matched to supplier sales invoices.
Taxpayers also still issue paper or PDF invoices to their suppliers, and must submit regular VAT returns, Intrastat and EC Sales Lists, as required. It is only a requirement for resident VAT registered businesses.
myData filing submissions
There are four routes for submitting e-invoices and e-books.
- Manual uploads for small numbers of invoices;
- From enabled ERP’s and accounting software linked to myDATA;
- Online certified cash registers which are connected to AADE; or
- Commercial providers of e-Invoicing services. These must be Greek-resident businesses. Providers must have demonstrated robust invoice creation, storage and retrieval systems to guarantee the integrity of invoices. The must also be Greek resident, and meet financial stability tests. Invoice data may be stored elsewhere in the EU.
From a technical perspective, the VAT books and the e-invoice data needs to be mapped and prepared in a pre-defined XML format. Then, this XML file needs to be submitted to the Greek AADE myDATA platform. The XML format follows the European EN 16931-1 standard.
The submission is on a monthly or on a quarterly basis – depending on the size of the taxpayer. The data submission should to be completed before the 20th day after the end of the month for ledgers in which the relevant invoices were issued. This will be supplemented with the online cash register VAT system for retail transactions.
AADE will use e-invoice to match with customer reporting to identify and return via myDATA any discrepancies. Check VAT Calc’s global live VAT invoice transaction and e-invoice reporting tracker to see where else real-time submissions of invoices is being implemented.
EU Digital Reporting Requirements
The ongoing EU VAT in the Digital Age proposals includes a strand around harmonised Digital Reporting Requirements (DRR) and Continuous Transaction Control (CTC) across the member states. This originated from the 2020 Tax Package measures for a fairer and more efficient EU tax regime.
