EU-Compendium E-Invoicing and Retention-Version 2 0 FINAL

Version 2.
0
November 2016
Editor Peters, Schönberger & Partner mbB

Schackstrasse 2, 80539 Munich
Tel.: +49 89 381720
Internet: www.psp.eu
E-INVOICING AND RETENTION IN EUROPE
P R EA M B L E
From a VAT perspective, invoice documents represent a major element of

taxation. Taxable supplies and services are regularly billed on invoices. If
in possession of a correct invoice document, the recipient of these billed
goods/services will receive an input VAT refund from the fiscal authorities.
The European VAT Directive (2006/112/EC) lays down the minimum

standard requirements for invoices in Art. 226, 230, 233, 244, and 246.
Although member states may impose fewer obligations (Art. 221), many
national legislators do indeed ask for more details on invoice documents.
Businesses in Europe find themselves in a similar situation with regard to

electronic invoices. While the European VAT Directive clearly states that a
business must guarantee the authenticity of the origin and the integrity of
the content of both electronic invoices and paper invoices, some member
states have issued specific national rules that seem to make it more
complicated to use electronic invoicing.
The same does also apply to retention requirements which are not
harmonized at all.
In the meantime, more and more businesses have been changing their
invoicing flows from paper to digital formats, which enables them to
automate the processing of their invoices.
This handbook shall give you an initial overview of the rules currently
applied in many European countries. For further questions and details,
please feel free to contact one of the local contributors.
November 2016
Philipp Matheis Janneke Speetjens

p.matheis@psp.eu j.speetjens@psp.eu
CON T R I B U T OR S
A U S T R I A
Pirklbauer
Wirtschaftsprüfung & Andreas Pirklbauer www.pirklbauer.com +43 7942747610
Steuerberatung
B E L G I U M
De btw-lijn Jurgen Opreel www.btw-lijn.be +32 477700492
C R O A T I A
iAudit d.o.o. Boris Vidas www.iaudit.hr +385 989798447
C Y P R U S
DFK Demetriou Trapezaris
Iacovos Raoukkas www.dfkcy.com +357 22879300
Ltd.
C Z E C H R E P U B L I C
Peterka & Partners
Marek Přemysl www.peterkapartners.com +420 246085300
advokátní kancelář s.r.o.
F I N L A N D
Jonne Granqvist
DFK Findlan Oy ab www.dfk.fi +358 9 604 204
Tom Lindblom
F R A N C E
SECAL Alexandre Jaeger www.secal.fr +33 (0)388548990
Conseils Associés SA Paul Grosjean www.cadfk.com +33 140679788
G E R M A N Y
Peters, Schönberger &
Philipp Matheis www.psp.eu +49 89381720
Partner mbB
Esche Schümann
Melanie Weist www.esche.de +49 40368050
Commichau
G R E E C E
DFK Global Accounting Dimosthenis
www.gasolutions.gr +30 2107249795
Solutions S.A. Papadimitriou
H U N G A R Y
Dr. Gyarmathy & Partner
Julia Keszei www.gyarmathy.hu +36 13492954
Ltd.
I R E L A N D
Crowleys DFK Siobhán O‘Hea www.crowleysdfk.ie +353 214272900
I T A L Y
N& CA Nicolini
Antonio Fontana www.studionicolini.com +39 0276021514
Commercialisti Associati
Rimbl, Holzeisen & Partners Richard Putz www.rimbl.com +39 0471977328
Studio Piccinelli Del Pico
Giusy Pisanti www.studioppp.it +39 022942691
Pardi & Partners
LATVIA
Gencs Valters Law Firm Valters Gencs www.gencs.eu +371 67 24 00 90
MA L T A
DFK Malta David Farrugia www.dfkmalta.com +356 21444962
N E T H E R L A N D S
Alfa Accountants en
Harm-Jan de Boer www.alfa.nl +31 882533900
Adviseurs
P O L A N D
Audit & Consulting, Pawlik,
Barbara Pawlik www.audit-consulting.eu +48 322039630
Modzelewski and Partners
PORTUGAL
DFK & Associados, SROC,
Marta Caldeira www.dfk.pt +351 211357677
Lda
R O M A N I A
Accordserve Advisory SRL Andreas Trapezaris www.accordserve.ro +40 317309000
S P A I N
Pedrosa Lagos Sonia Buxaderas www.pedrosalagos.com +34 933680510
Abante Auditores Jose M. Hinojal www.abanteauditores.com +34 902734200
S W E D E N
Cederblads Revisionsbyrå
Ingrid Petersson www.cederblads.se +46 44187270
AB
S W I T Z E R L A N D
Fidinter AG Raimondo Salis www.fidinter.ch +41 442972050
U N I T E D K I N G D O M
Wilson Wright LLP Nikki Crane www.wilsonwright.com +44 2078320444
CBW
Robert Maas www.cbw.co.uk +44 2073093800
Carter Backer Winter LLP
Langdowns DFK Limited Neil Raynsford www.langdownsdfk.com +44 2380613000
Disclaimer
The information in this handbook is for general guidance only. It is
essential to take professional advice on specific issues and their impact
on any individual or entity. No liability can be accepted for any errors
or omission or for any person acting or refraining from acting on the
information provided in this handbook.
Concept/Design: Peters, Schönberger & Partner mbB, Munich

T A B L E OF CON T EN T S
Austria 8
Belgium 14
Croatia 20
Cyprus 26
Czech Republic 32
Finland 38
France 44
Germany 50
Greece 56
Hungary 62
Ireland 68
Italy 74
Latvia 80
Malta 86
Netherlands 92
Poland 98
Portugal 104
Romania 110
Spain 116
Sweden 122
Switzerland 128
United Kingdom 134

A U STR I A
1. St a n d a r d r eq u ir em en t s f o r in v oices :
1. n.a. Designation as “invoice“

2.  Remark regarding “self-billing“, if applicable (Art. 226 no. 10a)
Full name and address of supplier (and/or service provider)
3. 
(Art. 226 no. 5)
National VAT number or alternatively EU VAT ID number of
4.  supplier (and/or service provider) (Art. 226 no. 3) in domestic
transactions
EU VAT ID number of supplier (and/or service provider) in EU
5. 
cross-border transactions (Art. 226 no. 3)
Full name and address of buyer (and/or service recipient)
6. 
(Art. 226 no. 5)
VAT number or alternatively EU VAT ID number of business
7. n.a.
buyer (and/or service recipient) in domestic transactions *
EU VAT ID number of buyer (and/or service recipient), if buyer is
8. 
a business, in EU cross-border transactions (Art. 226 no. 4)
9.  Invoice number (in sequential order) (Art. 226 no. 2)
10.  Invoice date (Art. 226 no. 1)
Date of supply or date of service (even if identical with invoice
11. 
date) (Art. 226 no. 7)
Quantity and nature of goods supplied and/or extent and nature
12. 
of services provided (Art. 226 no. 6)
13. n.a. Net amount per item
14.  Taxable (net) invoice amount in any currency allowed (Art. 230)
15. n.a. Taxable (net) invoice amount must be specified in EUR
Taxable (net) invoice amount must be specified in local (non-
16. n.a.
EUR) currency
Taxable amount must be specified separately for different VAT
17. n.a.
rates if applicable (Art. 226 no. 8)
18.  VAT rate(s) for the items on this invoice (Art. 226 no. 8)
19. n.a.VAT amount in any currency allowed (Art. 230)
* only under certain conditions
8
20.  VAT amount must be specified in EUR

21. n.a. VAT amount must be specified in local (non-EUR) currency
22. n.a. Total (gross) invoice amount
Remark on existing discount or bonus agreement (Art. 226 no. 8)
23. n.a. (stating the amount or percentage) if not yet included in total
amount
Remark on an existing VAT exemption on intra-Community
24.  supplies, triangulation cases, exports to non-EU countries or any
other reason (Art. 226 no. 11)
For VAT exemptions: Legal norm in national VAT law or in the
25. n.a.
VAT directive must be stated on the invoice
For VAT exemptions: Legal norm in national VAT law must be
26. n.a.
stated on the invoice
Remark on the application of the reverse charge procedure
27. 
(Art. 226 no. 11a)
For reverse charge: Legal norm in national VAT law or in the
28. n.a.
For reverse charge: Legal norm in national VAT law must be
29. n.a.
30.  Remarks on the application of a VAT margin scheme
31. n.a. Remark if the invoice was processed by computer
32. n.a. Number of bill of delivery
9
2. Sp ecia l r eq u ir em en t s f o r (in com in g a n d ou t go in g) elect r on ic

in v o ices
Q A
Is a digital signature required if the
authenticity of the origin and the
integrity of the content of an invoice
1. No digital signature required.
are ensured? If yes, which specific
type of digital signature and digital
certificate is required?
Is electronic invoicing subject to
approval of the invoice recipient? If
2. Yes; approval can be given tacitly.
yes, can the approval be given
tacitly?
Requirements on the data type (data
format) of electronic invoices:
No specific data format required –
Do they have to be in a “structured”
neither for incoming nor for outgoing
3. data format (such as XML)? If yes,
invoices (including storage of these
which format is appropriate?
invoices).
May the invoice be issued in a PDF Yes, PDF or PDF/A data format are fine
4.
or PDF/A data format? (for issuance as well as for storage).
No restrictions on data format; users
have free choice. However, the storage
and archiving of invoices which were
Are there any other restrictions
originally issued on paper, but scanned
5. regarding the data format? If yes,
for storage purposes, require some
what kind of restrictions?
specific archiving systems or storage
media, e.g. Write Once Read Many
(WORM) media.
10
3. Au t h en t icit y o f t h e o r ig in , in t egr it y of t h e con t en t a n d

legib ilit y o f a n (in co m in g) in v oice
Q A
Through business controls on these
invoices or (alternatively) Qualified
Electronic Signature (QES) when based
How can the authenticity of the
on a certificate verifiable via the
1. origin and integrity of the content be
“Signaturprüfdienst” of the RTR (or
ensured?
comparable foreign body) or Electronic
Data Exchange (EDI) in accordance
with 94/820/EC.
Internal control procedures with an
audit trail must be implemented:
Which business controls on invoices
2. Matching of the invoice with existing
must be implemented?
business documents (e.g. with the
purchase order).
Evidence of ensuring authenticity and
integrity has to be stored in electronic
Are there any documentation form in case of EDI and electronic
3. requirements for these business signatures but not in case of the
controls on invoices? business control options. There is no
obligation to document the business
controls.
Situation: Business controls are not
sufficient. However, the incoming
No impact on the deduction of input
4. invoices are correct. Will this affect
VAT if incoming invoices are correct.
the ability of the invoice recipient to
deduct input VAT?
Visual inspection of the document must
How can the legibility of an invoice be possible; electronic invoices must
5.
be ensured? have display functions (XML viewer,
text editor etc.).
11
4. Ar ch iv in g r eq u ir em en t s f o r ele ct r on ic in v oices
Q A
Are there any archiving requirements Basically, there are no restrictions
1. regarding the data type (data format) regarding the storage and archiving of
of electronic invoices? electronic invoices.
Do electronic invoices have to be
2.
archived in digital form?
Is it allowed to print the electronic It is allowed to print the electronic
3. invoices on paper and delete the invoice on paper and delete the
electronic data? electronic data.
Yes it is; in such a case, however, the
electronic invoices must be archived in
Is it allowed to convert electronic
both the original data format as well as
4. invoices into a new digital format for
in the new digital format. It must be
storage?
clear which version is the original
version.
Electronic invoices may generally be
Is it allowed to store the electronic
stored abroad without notification,
5. archive in a different EU member
provided that the tax authority is given
state?
online access.
Is a digital time stamp required? If
6. yes, at what point in time does the No digital time stamp required.
time stamp come into effect?
Visual inspection of the electronic
invoices as well as analysis functions
Are there any requirements regarding
7. on the electronic data must remain
the archiving system?
unchanged; no further requirements on
the archiving software.
7 years (22 years in respect of
8. What is the retention period? immovable property), normally starting
at the end of the year of receipt.
12
5. Sca n n in g o f p a p er in v o ices
Q A
Yes, but this requires some specific
Is it allowed to scan paper invoices
archiving systems or storage media,
1. and only keep the scan? If yes, what
e.g. Write Once Read Many (WORM)
are the requirements to do this?
media.
13
B EL GI U M
(St a t u s a s o f Ap r il 2016)
1.  Designation as “invoice“
3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. 
buyer (and/or service recipient) in domestic transactions
8. 
11. 
12. 
13.  Net amount per item
16. n.a.
EUR) currency
17. 
19.  VAT amount in any currency allowed (Art. 230)
14
20. n.a. VAT amount must be specified in EUR

23.  (stating the amount or percentage) if not yet included in total
amount
25. n.a.
26. n.a.
27. 
(Art. 226 no. 11a)
28. n.a.
29. n.a.
15

in v o ices
Q A
tacitly?
No specific data format required; users
have free choice.
Yes, PDF or PDF/A data formats are
May the invoice be issued in a PDF fine, but one must still be able to prove
4.
or PDF/A data format? the origin and integrity of the content
of the invoice.
have free choice.
16

Q A
invoices, AES and EDI.
ensured?
Matching of the invoice with existing
2. purchase order). This procedure may
change over the years because of the
development of the company. This
method can vary in function of the size
and the activities of the company.
A detailed process documentation must
Are there any documentation be presented when asked by the tax
3. requirements for these business authorities, and also proof that the
controls on invoices? company has control over its internal
control procedures.
VAT if incoming invoices are correct
and if it can be proven that the content
of the invoice reflects the real situation.
deduct input VAT?
5.
text editor etc.).
17
Q A
Are there any archiving requirements
No specific data format required; users
1. regarding the data type (data format)
have free choice.
of electronic invoices?
2. No, this is not necessary.
Is it allowed to print the electronic
Yes, but the tax authority still has to
3. invoices on paper and delete the
publish its guidelines on this matter.
electronic data?

Yes, but the tax authority still has to
publish its guidelines on this matter.
storage?
Electronic invoices may be stored

abroad without notification, provided
that the tax authority is guaranteed
state?
online access.
Are there any requirements regarding invoices must be possible and the
7.
the archiving system? archiving system has to guarantee the
integrity of the content of the invoices.
7 years (15 years for investment goods
subject to the revision term of 15 years,
8. What is the retention period? i.e. new buildings), starting from the 1st
of the year following the year in which
the invoice was issued.
18
Q A
Yes, the archiving system has to
Is it allowed to scan paper invoices guarantee the integrity of the content of
1. and only keep the scan? If yes, what the invoices; paper invoices need to be
are the requirements to do this? kept for one month after the date of
scanning.
19
CR O A T I A

3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. 
8. 
11. 
12. 
16. 
EUR) currency
17. 
20

21.  VAT amount must be specified in local (non-EUR) currency
22.  Total (gross) invoice amount
amount
25. n.a.
26. 
27. 
(Art. 226 no. 11a)
28. n.a.
29. 
Other remarks:
For the purposes of the taxation procedure, an invoice must also
contain the following:
- time when the receipt was issued (hour and minute);
- identification of the cash register operator (a person);
- means of payment identifier: banknotes, card, cheque,
transactional account, other;
33. 
- unique receipt identifier, and security code of the issuer, e.g.
the taxpayer subject to taxation;
- if the VAT cash accounting scheme is applicable to a legal
entity: “Calculation based on the cash accounting scheme”;
- if the VAT cash accounting scheme is applicable to a taxpayer
subject to personal income tax: “R-2: Calculation based on the
cash accounting scheme”.
21

in v o ices
Q A
tacitly?
invoices).
4.
have free choice.
22

Q A
QES, EDI and any method at the choice
of the taxable person.
ensured?
Business controls must ensure a
reliable audit trail and linking the
2. invoice with existing business
documents (e.g. with the purchase
order).
A detailed invoice supporting
Are there any documentation
documentation must be prepared and
3. requirements for these business
kept up-to-date (contracts, orders,
controls on invoices?
receipt notes etc.).
deduct input VAT?
5.
text editor etc.).
23
Q A
1. regarding the data type (data format) No specific requirements.
Do electronic invoices have to be No; invoices may be stored in paper or
2.
archived in digital form? electronic form.
3. invoices on paper and delete the Yes; this is permissible.
electronic data?

Yes it is; there are no further
requirements.
storage?
Is it allowed to store the electronic Yes, provided that the tax authority is
5. archive in a different EU member notified and given online access if
state? required.
Competent supervision authorities must
be given online access to the date
Are there any requirements regarding concerned and – upon a request –
7.
the archiving system? access, download and use of those
invoices must be granted by the taxable
person.
11 years after the year to which the
8. What is the retention period?
invoice pertains.
24
Q A
1. and only keep the scan? If yes, what Yes; there are no further requirements.
25
CY P R U S
3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. n.a.
8. 
11. 
12. 
16. n.a.
EUR) currency
17. 
19.  VAT amount in any currency allowed (Art. 230) *
26
20.  VAT amount must be specified in EUR

amount
25. n.a.
26. n.a.
27. 
(Art. 226 no. 11a)
28. n.a.
29. n.a.
27

in v o ices
Q A
tacitly?
invoices).
4.
have free choice.
28

Q A
The authenticity and integrity of
electronic invoices can be secured with
the use of any relevant technology.
How can the authenticity of the Therefore, it is to the discretion of the
1. origin and integrity of the content be Company to choose the technology to
ensured? be applied, and there is no obligation
to apply only the Electronic Data
Interchange (EDI) or advanced
electronic signatures.
All business controls that ensure the

2. integrity and authenticity of the invoice
are accepted.
Are there any documentation There is no requirement by law. It is

3. requirements for these business to the discretion of the Company to
controls on invoices? include e-Invoicing in its manual.
deduct input VAT?
5.
text editor etc.).
29
Q A
Do electronic invoices have to be Yes; electronically invoices must be
2.
archived in digital form? stored in their original data format.
3. invoices on paper and delete the No, this is not allowed.
electronic data?
Yes, but invoices must be converted in
a way which safeguards all the original
data and the data that has been
storage?
converted.
Yes; storage is allowed in the EU and in
Is it allowed to store the electronic countries with which Cyprus has a
5. archive in a different EU member relevant tax assistance treaty;
state? notification and online access are
necessary.
Are there any requirements regarding VAT commissioner must be informed if

7.
the archiving system? invoices are stored outside Cyprus.
8. What is the retention period? Invoices must be stored for six years.
30
Q A
No; invoices sent on paper must be
stored as they were when received.
31
CZ ECH R EP U B L I C

3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. 
8. 
Date of supply or date of service (only if different from invoice
11. 
12. 
13.  Net amount per item
16. n.a.
EUR) currency
17. 
32

amount or amount per item
25. 
26. n.a.
27. 
(Art. 226 no. 11a)
28. n.a.
29. n.a.
33

in v o ices
Q A
Is a digital signature required if the No, provided that the authenticity of
authenticity of the origin and the origin, the integrity of the content and
integrity of the content of an invoice the legibility of an invoice is ensured
1.
are ensured? If yes, which specific by other controlling processes creating
type of digital signature and digital a reliable link between the invoice and
certificate is required? the respective supply.
tacitly?
3. data format (such as XML)? If yes, No specific data format required.
4.
have free choice.
34

Q A
Electronic signature, electronic mark,
EDI and control mechanisms of
processes that create a reliable link
ensured?
between the invoice and the supply.

2. reliable audit trail linking an invoice
and a supply.

3. requirements for these business No, no specific requirements apply.
and if it can be proven that the content
of the invoice reflects the real situation.
deduct input VAT?
Through control mechanisms of
processes that create a reliable link
How can the legibility of an invoice between the invoice and the supply.
5.
be ensured? An invoice is legible if its content is
visible directly or through a
technological equipment.
35
Q A
No. Electronic invoices may be
converted and archived even as hard
copies (paper) under the condition that
2. the authenticity of the origin and
integrity of content is ensured (audit
trail). An authorized conversion (e.g. by
the Czech Point) might also be used.
3. invoices on paper and delete the Yes it is; under the above conditions.
electronic data?

Yes, if the authenticity of the origin and
integrity of content is ensured.
storage?
Invoices may be stored outside the

Czech Republic, if there is a
continuous remote access and after a
state?
prior notification to the tax authority.
Digital time stamp is not obligatory.
However, it might be used to prove the
6. yes, at what point in time does the
authenticity and integrity of
documents.
If the invoices are archived
electronically, the data ensuring the
7. authenticity of origin and integrity of
the content have to be archived in the
same way.
10 years; normally starting at the end of
the relevant tax period.
36
Q A
Yes; under the condition that the
authenticity of the origin and integrity
of content of the invoice are ensured.
This can be done by an authorised
conversion (e.g. by the Czech Point) or
by a sufficient audit trail.
37
F I NL A ND

3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. 
8. 
11. 
12. 
16. n.a.
EUR) currency
17. 
19. n.a.VAT amount in any currency allowed (Art. 230) *
38

amount
25. 
26. n.a.
27. 
(Art. 226 no. 11a)
28. 
29. n.a.
39

in v o ices
Q A
tacitly?
May the invoice be issued in a PDF
4. Yes, PDF or PDF/A formats are fine.
or PDF/A data format?
5. regarding the data format? If yes, No restrictions.
40

Q A
How can the authenticity of the Business controls by the invoice
1. origin and integrity of the content be recipient can ensure authenticity and
ensured? integrity.

2. No specific rules.

3. requirements for these business No specific rules.
deduct input VAT?
5.
be ensured? have display functions (XML viewer
text editor etc.).
41
Q A
Do electronic invoices have to be No; electronic invoices may be
2.
archived in digital form? converted and archived as hard copies.
Yes; provide that upon request it is
made available to the tax authority.
electronic data?

Yes; provide that upon request it is
made available to the tax authority.
storage?
Yes; Data must have perfect

accessibility in real time and that upon
request it is made available to the tax
state?
authority.
If the invoices are archived

7. electronically the data must have
perfect accessibility in real time.
6 years from end of the years to which

the invoice relates.
42
Q A
Is it allowed to scan paper invoices Yes; under the condition that the
1. and only keep the scan? If yes, what authenticity of the origin and integrity
are the requirements to do this? of content of the invoice are ensured.
43
F R A N CE

2. n.a. Remark regarding “self-billing“, if applicable (Art. 226 no. 10a)
3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. n.a.
8. 
11. 
12. 
16. n.a.
EUR) currency
17. 
44

amount
25. 
26. n.a.
27. 
(Art. 226 no. 11a)
28. 
29. n.a.
45

in v o ices
Q A
Yes, a remark (in writing) that the
recipient‘s silence is taken as an
2. approval is necessary. No
consequences for the service recipient
tacitly?
if such a document does not exist.
Do they have to be in a “structured” invoices). The recipient of an electronic
3. data format (such as XML)? If yes, invoice may even choose to print the
which format is appropriate? invoice on paper and delete the data
file. In this case, the invoice will not be
regarded as an electronic invoice on
the invoice recipient’s side.
May the invoice be issued in a PDF Yes, PDF or PDF/A data formats are
4.
or PDF/A data format? fine (for issuance as well as for storage).
No restrictions on data format as long
as the recipient accepts.
46

Q A
invoices, QES, RGS (a specific French
electronic signature which is not
How can the authenticity of the qualified),“proper EDI” with an
1. origin and integrity of the content be interchange agreement based on the
ensured? European Commission 1994
Recommendation subject to summary
statements and “partner file”
requirements.
purchase order).
be prepared and kept up-to-date.
and the supplies or services were really
received.
deduct input VAT?
5.
text editor etc.).
47
Q A
Electronic invoices must be archived in
the original data format. However, the
recipient of an electronic invoice may
choose to print the invoice on paper
and delete the data file. In this case, the
invoice will not be regarded as an
electronic invoice on the invoice
recipient’s side.
Yes; electronic invoices must be
archived in the original data format.
However, the recipient of an electronic
Do electronic invoices have to be invoice may choose to print the invoice
2.
archived in digital form? on paper and delete the data file. In
this case, the invoice will not be
No; electronic invoices must be
However, the recipient of an electronic
invoice may choose to print the invoice
on paper and delete the data file. In
electronic data?
this case, the invoice will not be
Is it allowed to convert electronic No; electronic invoices must be

4. invoices into a new digital format for archived in the original data format for
storage? 3 years.

abroad in other EU states, provided that
the tax authority is notified and given
state?
online access.
48

the original format for 3 years. After 3
8. What is the retention period? years, invoices can be archived in
electronic or other versions. Overall
retention period is 10 years.
Q A
No. Invoices must be archived in the
original format.
49
GER M A NY

3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. n.a.
8. 
11. 
12. 
16. n.a.
EUR) currency
17. 
50

amount
25. 
26. n.a.
27. 
(Art. 226 no. 11a)
28. n.a.
29. n.a.
Other remarks:
The recipient’s legal obligation to retain the invoice for 2 years
33.  (beginning with the start of the next calendar year), even if the
recipient is not a business – this only applies for supplies with
installation and/or services connected to immovable property
51

in v o ices
Q A
tacitly?
4. Yes, PDF or PDF/A data format are fine.
have free choice.
52

Q A
How can the authenticity of the Through business controls on these
1. origin and integrity of the content be invoices. Alternatively through QES or
ensured? EDI.
purchase order).
deduct input VAT?
5.
text editor etc.).
53
Q A
the original data format.
Do electronic invoices have to be Yes; electronic invoices must be
2.
archived in digital form? archived in the original data format.
electronic data?
Is it allowed to convert electronic electronic invoices must be archived in
4. invoices into a new digital format for both the original data format as well as
storage? in the new digital format and both files
must be stored under the same index.
Is it allowed to store the electronic Yes, if the data can be made available
5. archive in a different EU member to the national tax authorities without
state? delay.
10 years, normally starting at the end of
the year of receipt.
54
Q A
Yes, business controls must be
implemented and a detailed process
kept up-to-date. Other (non-VAT) rules
may require that certain documents are
kept in the original paper format.
55
G R EECE

3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. 
8. 
11. n.a.
12. 
16. n.a.
EUR) currency
17. 
19. n.a. VAT amount in any currency allowed (Art. 230)
56

amount
25. 
26. n.a.
27. 
(Art. 226 no. 11a)
28. n.a.
29. n.a.
Other remarks:
The information stipulated by the pertinent VAT legislation
33. 
based on the VAT Directive in case of an IC-supply of a new
means of transportation
57

in v o ices
Q A
tacitly?
4. Yes, PDF or PDF/A data format are fine.
No, except that legibility must be
ensured.
58

Q A
Indicatively, through Advanced
Electronic Signature (AES) based on a
How can the authenticity of the qualified certificate, EDI , special safe
1. origin and integrity of the content be appliances (Electronic Tax Machines),
ensured? clearance of sales transactions through
a payment service provider or other
business controls.
Which business controls on invoices reliable audit trail linking an invoice
2.
must be implemented? and a supply of goods/services so that
integrity and authenticity are ensured.
Are there any documentation Yes; evidence of ensuring integrity and
3. requirements for these business authenticity has to be stored in any
controls on invoices? form for at least 5 years.
and the fact that the supply/service was
really rendered can be proven in case
of a tax audit; otherwise, risk of no
deduct input VAT?
deduction of input VAT.
5.
text editor etc.) or must be printable.
59
Q A
No, except that legibility must be
Are there any archiving requirements ensured as well as that the data
1. regarding the data type (data format) ensuring the authenticity of origin and
of electronic invoices? the integrity of content must in any
case be archived/preserved.
No; however, the data ensuring the
Do electronic invoices have to be authenticity of origin and the integrity
2.
archived in digital form? of content must in any case be
archived/preserved.
Yes; however, the data ensuring the
authenticity of origin and the integrity
of content must in any case be
electronic data?
archived/preserved.
Yes it is; however, the data ensuring
the authenticity of origin and the
integrity of content must in any case be
storage?
archived/preserved.
Is it allowed to store the electronic Yes, provided that upon request it is
5. archive in a different EU member made available to the tax authority (tax
state? auditors) in due course.
The system must allow searching,
Are there any requirements regarding displaying and printing out or
7.
the archiving system? reproduction of the invoices for tax
audit purposes.
5 years starting from the end of the year
8. What is the retention period? in which the tax return is to be filed
with (standard rule).
60
Q A
Yes; authenticity of origin and integrity
as well as legibility must in any case be
ensured; the data ensuring the
authenticity of origin and the integrity
of content must in any case be
archived/preserved.
61
H U NGA R Y
3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. n.a.
8. 
11. 
12. 
16. 
EUR) currency
17. 
62

21.  VAT amount must be specified in local (non-EUR) currency
22.  Total (gross) invoice amount
amount
25. n.a.
26. 
27. 
(Art. 226 no. 11a)
28. 
29. 
31.  Remark if the invoice was processed by computer
63

in v o ices
Q A
Digital signature required or the e-
1. invoice has to be generated and
forwarded as EDI electronical data.
approval of the invoice recipient? If Yes; approval can be given tacitly (e.g.
2.
yes, can the approval be given by paying the invoice).
tacitly?
3. data format (such as XML)? If yes, No; for details see below.
4.
Yes; only .txt, .csv, .dbf, .mdb, .xsl,
.xml, .pdf, and any other print file that
contains unformatted text or characters
are accepted.
64

Q A
QES, proper EDI, and any other
business controls.
ensured?

2. reliable audit trail links the invoice and
the supply of goods/services.

deduct input VAT?
5.
text editor etc.).
65
Q A
Invoices must be archived in the data
format they were received.
2.
electronic data?
Is it allowed to convert electronic It can be archived in a new digital

4. invoices into a new digital format for format if the conversion is accepted by
storage? VAT Law.
Yes; information about the place where

Is it allowed to store the electronic invoices are archived must be
5. archive in a different EU member provided. The invoices have to be
state? made available to the tax authority (tax
auditors) upon request.
Time-stamping for invoices was
removed from VAT legislation by 1st
January 2013; but it currently still
remains for storage.
The invoices must be stored in their

7. original forms; that is the form they
were issued.
5 years for tax purposes, 8 years for

accounting purposes.
66
Q A
No, it is not. Invoices must be kept in
the form they were received.
67
I R EL A ND

3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. n.a.
8. 
11. 
12. 
16. n.a.
EUR) currency
17. 
68

amount
25. n.a.
26. n.a.
27. 
(Art. 226 no. 11a)
28. n.a.
29. n.a.
69

in v o ices
Q A
Yes, there must be “prior agreement”
between the person issuing the invoice
2. and the invoice recipient. Legislation
does not specify whether / how the
tacitly?
“prior agreement” must be evidenced.
Do they have to be in a “structured” No specific data format required for
3. data format (such as XML)? If yes, outgoing invoices (including storage of
which format is appropriate? these invoices).
4.
have free choice.
70

Q A
invoices. AES and EDI systems must
have certain capabilities that are
specified in legislation. A business can
use other systems provided the systems
ensured?
have the capabilities that are specified
in legislation and that the business
notifies the tax authority.
The business controls must ensure the
authenticity of the origin of invoices,
Which business controls on invoices the integrity of the content of invoices,
2.
must be implemented? and that there is a reliable audit trail for
invoices and the supply of goods or
services as described therein.
4. invoices are correct. Will this affect Legislation does not specify.
deduct input VAT?
be possible; electronic invoices must
have display functions (XML viewer,
text editor etc.) A person who issues or
How can the legibility of an invoice receives electronic invoices must be
5.
be ensured? able to reproduce any such invoice in
paper or electronic format on request
by an officer of the tax authority and in
such format as specified by the officer
at the time of the request.
71
Q A
2.
electronic data?
that the tax authority is given access at
state?
all reasonable times.
6 years from the date of the latest
8. What is the retention period? transaction to which they refer (with
certain exceptions).
72
Q A
Yes. If the quality of an original of a
record is too poor to be scanned, or if
the colour or ink cannot produce
legible scanned images and a
Is it allowed to scan paper invoices photocopy is used instead, this should
1. and only keep the scan? If yes, what be recorded and the original record
are the requirements to do this? (and its photocopy) retained. If the
original contains physical changes that
would not be visible on the scanned
image or a reproduction, it should also
be retained.
73
I T A L Y
1.  Designation as “invoice“
3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
VAT ID number of business buyer (and/or service recipient) in
7. 
domestic transactions
8. 
11. n.a.
12. 
14. n.a.Taxable (net) invoice amount in any currency allowed (Art. 230)
15.  Taxable (net) invoice amount must be specified in EUR
16. n.a.
EUR) currency
17. 
74

amount
25. n.a.
VAT directive must be stated on the invoice *
26. n.a.
27. 
(Art. 226 no. 11a)
28. n.a.
VAT directive must be stated on the invoice *
29. n.a.
32. n.a. Number of bill of delivery **
* not mandatory, but required from a practical point of view
** only under certain conditions
75

in v o ices
Q A
No digital signature required on
invoices sent by electronic means.
instead). However, whenever
electronic invoices are legally required
(such as in B2G invoices), a digital
1. signature is mandatory. Italy will accept
a QES as well as a so-called Digital
Signature based on a qualified
certificate and a cryptographic key
system (using locally approved
hardware instead).
Yes it is subject to approval; approval
cannot be given tacitly, however, in
case of not acceptance by the recipient
the issuer may still send the invoice
through electronic means. If the
2. recipient of an electronic invoice does
not approve, he may choose to print
tacitly?
the invoice on paper and delete the
data file. In this case, the invoice will
not be regarded as an electronic
invoice on the invoice recipient’s side.
invoices).
4.
have free choice.
76

Q A
invoices, EU QES, Digital Signature
based on a qualified certificate and a
cryptographic key system “proper EDI”
How can the authenticity of the with an interchange agreement based
1. origin and integrity of the content be on the European Commission 1994
ensured? Recommendation; other technologies
chosen by the issuer that can guarantee
the authenticity of origin and the
integrity under the responsibility of the
same issuer.
Which business controls on invoices Matching of the invoice with existing
2.
must be implemented? business documents (e.g. with the
purchase order) and the integrated
accounting system (e.g. ERP).
deduct input VAT?
5.
text editor etc.).
77
Q A
2.
Yes, in case the recipient does not
accept the electronic invoices. In this
case, the invoice will not be regarded
as an electronic invoice on the invoice
electronic data?
recipient’s side. It is not allowed for the
invoice provider.
abroad in other EU states as well as in
any country with which Italy has
signed a mutual tax assistance treaty,
state?
subject to prior notification and online
access from Italy.
A digital time stamp on all electronic
files is required for every filing period
within 3 months of the filing of the tax
return (usually 31 December).
78
Q A
Yes, electronic storage of documents
by means of scanning of incoming
invoice is allowed following the same
rules provided for the electronic
invoices. Business controls must be
kept up-to-date.
79
L A TV I A

2. Remark regarding “self-billing“, if applicable (Art. 226 no. 10a)
3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. 
8. 
9. Invoice number (in sequential order) (Art. 226 no. 2)
10. Invoice date (Art. 226 no. 1)
11. 
12. 
14. n.a.Taxable (net) invoice amount in any currency allowed (Art. 230)
15.  Taxable (net) invoice amount must be specified in EUR
16. n.a.
EUR) currency
17. 
18. VAT rate(s) for the items on this invoice (Art. 226 no. 8)
80

amount
25. 
26. n.a.
27. 
(Art. 226 no. 11a)
28. 
29. n.a.
30. Remarks on the application of a VAT margin scheme
31.  Remark if the invoice was processed by computer
81

in v o ices
Q A
1. No.
approval of the invoice recipient? If Yes, it is subject to approval,
2.
yes, can the approval be given preferably in writing.
tacitly?
3. data format (such as XML)? If yes, No.
4. Yes.
5. regarding the data format? If yes, No restrictions are applicable.
82

Q A
How can the authenticity of the Business controls by the invoice
1. origin and integrity of the content be recipient can ensure authenticity and
ensured? integrity (e.g. digital signature).
Any business controls are allowed that
Which business controls on invoices can ensure the connection between
2.
must be implemented? the invoice and goods and/or services
provided.
3. requirements for these business No.
4. invoices are correct. Will this affect No.
deduct input VAT?
Visual inspection must be possible.
The invoice has to be displayed in
such a manner that all information is
How can the legibility of an invoice
5. clear to both parties. In order to ensure
be ensured?
correctness of the provided
information, it cannot be possible to
make amendments to the invoice.
83
Q A
Yes, it needs the same format as the
original invoice.
2. Yes.
3. invoices on paper and delete the No.
electronic data?

4. invoices into a new digital format for Only the same format.
storage?

Yes, it is allowed. But it has to be
secured and accessible at any time.
state?
6. yes, at what point in time does the No.
Are there any requirements regarding Authenticity and content integrity

7.
the archiving system? must be secured.
8. What is the retention period? 10 years.
84
Q A
Yes. But in order to keep documents
Is it allowed to scan paper invoices only electronically it has to be ensured
1. and only keep the scan? If yes, what that all data are visible and, if
are the requirements to do this? necessary, the paper copy can be
created.
85
M A L T A

3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. 
8. 
11. n.a.
12. 
16. n.a.
EUR) currency
17. 
86

23. n.a.(stating the amount or percentage) if not yet included in total
amount
25. 
26. n.a.
27. 
(Art. 226 no. 11a)
28. 
29. n.a.
Other remarks:
Where the VAT becomes chargeable at the time when payment
is received the mention “Cash Accounting“ (Parts One and Three
of the Fourteenth Schedule to the Maltese VAT Act). In an
33. 
invoice for the intra-Community supply of a new means of
transport, a description of the goods supplied shall contain the
particulars referred to in the definition of “new means of
transport“ under Art. 2 of the Maltese VAT Act.
87

in v o ices
Q A
Yes; the use of an eInvoice is subject to
Is electronic invoicing subject to acceptance by the recipient. The local
approval of the invoice recipient? If law does not specify the need for an
2.
yes, can the approval be given agreement prior to the issuance of an
tacitly? eInvoice, indicating that the approval
may be given tacitly.
invoices).
4.
have free choice.
88

Q A
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
ensured?
controls which create a reliable audit
trail between an invoice and a supply
of goods or services.
Other than as provided in our reply
Which business controls on invoices above, QES, EDI are examples of
2.
must be implemented? accepted means to ensure the integrity
and authenticity of electronic invoices.
deduct input VAT?
5.
text editor etc.).
89
Q A
Are there any archiving requirements Invoices shall be stored in the original
1. regarding the data type (data format) form in which they were sent or made
of electronic invoices? available.
Invoices shall be stored in the original
2. form in which they were sent or made
available
No. Invoices shall be stored in the
original form in which they were sent
or made available, whether paper or
electronic data?
electronic.
5. archive in a different EU member Yes; there are no specific requirements.
state?

7. No specific requirements.
At least 6 years from end of the year to

which the invoice relates.
90
Q A
No; invoices have to be kept in the
original form.
91
NET H ER L A ND S

3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. n.a.
8. 
11. 
12. 
16. n.a.
EUR) currency
17. 
92

amount
Remark on an existing VAT exemption (or zero-rate) on intra-
24.  Community supplies, triangulation cases, exports to non-EU
countries or any other reason (Art. 226 no. 11)
25. n.a.
26. n.a.
27. 
(Art. 226 no. 11a)
28. n.a.
29. 
Remarks on the application of a VAT margin scheme (including
30. 
national legal norm)
93

in v o ices
Q A
tacitly?
invoices).
4.
have free choice.
94

Q A
How can the authenticity of the There are no specific rules. For
1. origin and integrity of the content be example, through business controls on
ensured? these invoices, as EDI.
There are no specific rules. It is
Which business controls on invoices preferred to have a reliable audit trail
2.
must be implemented? based on business controls which links
an invoice and a supply.
There are no specific rules. It is
preferred to have a detailed process
documentation which is to be kept up-
to-date.
deduct input VAT?
5.
text editor etc.).
95
Q A
2.
electronic data?
abroad in other EU states as well as in
any country with which the
Netherlands has signed a mutual tax
state?
assistance treaty, subject to online
access.
the year of receipt (10 years if the
invoices relates to real estate or
electronic services).
96
Q A
kept up-to-date.
97
P OL A ND
1. n.a. Designation as "invoice"

2.  Remark regarding "self-billing", if applicable (Art. 226 no. 10a)
Full name and address of supplier (and/or service provider) (Art. 226 no.
3. 
5)
National VAT number or alternatively EU VAT ID number of supplier
4. n.a.
(and/or service provider) (Art. 226 no. 3) in domestic transactions
EU VAT ID number of supplier (and/or service provider) in EU cross-
5. 
border transactions (Art. 226 no. 3)
6.  Full name and address of buyer (and/or service recipient) (Art. 226 no. 5)
VAT number and additionally EU VAT ID of buyer (service
7. n.a.
recipient) in national transactions
EU VAT ID number of buyer (and service recipient), if buyer is a
8. 
business, in EU cross-border transactions (Art. 226 no. 4)
The date on which the supply of goods or services was made or
11.  completed in so far as that date can be determined and differs
from the date of the invoice (Art. 226, paragraph. 7)
Quantity and nature of goods supplied and/or extent and nature of
12. 
services provided (Art. 226 no. 6)
Amounts which appear on the invoice may be expressed in any
14.  currency, provided that the amount of VAT due is expressed in
the national currency (Art. 230)
15. n.a. Taxable (net) invoice amount can be expressed in EURO.
16. n.a.
EUR) currency
Taxable amount must be specified separately for different VAT rates if
17. 
applicable (Art. 226 no. 8)
18. n.a. VAT rate(s) for the items on this invoice (Art. 226 no. 8)
98

Remark on existing discount or bonus agreement (Art. 226 no. 8) (stating
23. 
the amount or percentage) if not yet included in total amount
Remark on an existing VAT exemption on intra-Community supplies,
24.  triangulation cases, exports to non-EU countries or any other reason (Art.
226 no. 11)
For VAT exemptions: Legal norm in national VAT law or in the VAT
25. 
directive must be stated on the invoice
For VAT exemptions: Legal norm in national VAT law must be stated on
26. n.a.
the invoice
Remark on the application of the reverse charge procedure (Art. 226 no.
27. 
11a)
For reverse charge: Legal norm in national VAT law or in the VAT
28. 
directive must be stated on the invoice
For reverse charge: Legal norm in national VAT law must be stated on
29. n.a.
the invoice
99

in v o ices
Q A
Yes, an approval of the invoice
2. recipient is necessary (e.g. in a
contract).
tacitly?
4.
have free choice. Regulations concern
both e.g.: monthly storage and easy
access.
100

Q A
QES, EDI, and business controls
ensuring a reliable audit trail linking
an invoice and a supply are examples
of accepted means to ensure the
ensured?
integrity and authenticity of electronic
invoices.
purchase order).
deduct input VAT?
5.
text editor etc.).
101
Q A
the original data format as advised.
2.
electronic data?
abroad, provided that the tax authority
Is it allowed to store the electronic is given online access. The tax
5. archive in a different EU member authority must at all times be informed
state? about the place of storage of invoices,
no matter if located in Poland or
abroad.
As a general rule all records required to
be kept must be retained for five years
after the end of the calendar year in
which the tax was due.
102
Q A
kept up-to-date.
103
P OR TUGAL
2. Remark regarding “self-billing“, if applicable (Art. 226 no. 10a)
3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. 
8. 
9. Invoice number (in sequential order) (Art. 226 no. 2)
10. Invoice date (Art. 226 no. 1)
11. 
12. 
14. Taxable (net) invoice amount in any currency allowed (Art. 230)
16. n.a.
EUR) currency
17. 
18. VAT rate(s) for the items on this invoice (Art. 226 no. 8)
104

amount
25. 
26. n.a.
27. 
(Art. 226 no. 11a)
28. 
29. n.a.
30. Remarks on the application of a VAT margin scheme
31.  Remark if the invoice was processed by computer
105

in v o ices
Q A
2. Yes, approval can be given tacitly.
tacitly?
No specific data format is required.
Do they have to be in a “structured” However, it is necessary to prove the
3. data format (such as XML)? If yes, authenticity of the origin, content
which format is appropriate? integrity and legibility of electronic
invoices.
May the invoice be issued in a PDF Yes, however the conditions
4.
or PDF/A data format? mentioned above must be applied.
5. regarding the data format? If yes, No restrictions on data format.
106

Q A
The authenticity of origin and integrity
can be assured as follows: EDI;
Electronic signatures or management
controls which is possible a reliable
ensured?
audit in respect of invoices
electronically issued.
All controls must ensure the integrity
and authenticity of the invoice are
accepted.
Example: The recipient of invoices
2. should have control in order to proof
if the services/ transmissions of goods
are done by company that issued the
invoice (purchase order; delivery
notes…).
Are there any documentation A detailed invoice supporting
3. requirements for these business documentation must be prepared and
controls on invoices? kept up-to-date (contracts,…).
deduct input VAT?
Visual inspection of the document
How can the legibility of an invoice must be possible; electronic invoices
5.
be ensured? must have display functions (XML
viewer, text editor, …).
107
Q A
the original data format as advised.
2. Yes.
3. invoices on paper and delete the No.
electronic data?
The electronic invoice should be
4. invoices into a new digital format for archived in your original format in
storage? order to ensure all original elements.
Is it allowed to store the electronic It is necessary to ask authorization to

5. archive in a different EU member Portuguese tax Authorities in order to
state? establish specific conditions.
6. yes, at what point in time does the No.
The archiving of invoices issued
electronically should be made in order
to ensure: a) the implementation of
controls that ensure the integrity and
assurance of archiving; b) the
Are there any requirements regarding implementation of features in order to
7.
the archiving system? avoid any change, destruction or
deterioration of archival records;
c) the recovery of data in case of
incident; d) the reproduction of legible
and intelligible copies of the recorded
data.
8. What is the retention period? 10 years.
108
Q A
1. and only keep the scan? If yes, what No.
109
R OM A NI A
1.  Designation as “invoice“
3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. 
8. 
11. 
12. 
16. 
EUR) currency
17. 
110

Remark on existing discount or bonus agreement (Art 226 no. 8)
amount
25. n.a.
26. 
27. 
(Art. 226 no. 11a)
28. n.a.
29. 
31.  Remark if the invoice was processed by computer
32.  Number of bill of delivery
111

in v o ices
Q A
authenticity of the origin and the An extended digital signature based on
integrity of the content of an invoice a qualified certificate, issued by an
1.
are ensured? If yes, which specific accredited suppliers of certification
type of digital signature and digital services is required.
Is electronic invoicing subject to There is no reference in the law
approval of the invoice recipient? If regarding the approval of the invoice
2.
yes, can the approval be given recipient. Approval can be given
tacitly? tacitly.
Electronic invoices may be in any
format, but XML and PDF are preferred.
4.
5 No restrictions on data format; users
regarding the data format? If yes,
. have free choice.
112

Q A
QES, EDI, and business controls that
ensure the integrity and authenticity.
ensured?
Business controls can be used to

2. establish reliable audit trails linking
invoices and supplies.
It is explicitly stated in the legislation

Are there any documentation that for invoices stored in electronic
3. requirements for these business form the evidence of ensuring the
controls on invoices? authenticity and integrity also has to be
stored in electronic form.
deduct input VAT?
How can the legibility of an invoice Visual inspection of the document must
5.
be ensured? be possible.
113
Q A
Do electronic invoices have to be No; invoices may be stored in paper or
2.
archived in digital form? electronic form.
Yes, invoices may be converted,
irrespective of the original data format.
electronic data?

4. invoices into a new digital format for Yes, this is permissible.
storage?
Storage abroad is permitted only in

countries with which Romania has a
mutual tax assistance treaty; tax
authorities must be notified one month
state?
before outsourcing via registered mail;
online access must be given.
Authenticity, integrity, and legibility
Are there any requirements regarding must be guaranteed for the whole
7.
the archiving system? storage period; apart from this, there
are no further requirements.
10 years; normally starting at the end of
114
Q A
1. and only keep the scan? If yes, what Yes; this is permissible.
115
SP A I N

3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. 
8. 
11. n.a.
12. 
16. n.a.
EUR) currency
17. 
18. n.a.VAT rate(s) for the items on this invoice (Art. 226 no. 8)
116

amount
25. 
26. n.a.
27. 
(Art. 226 no. 11a)
28. n.a.
29. n.a.
30. n.a.Remarks on the application of a VAT margin scheme
Other remarks:
- Commercial Registry Data of the taxpayer issuing the invoice
33. 
- If the invoice is issued by the addressee or a third party, it
must be stated in the invoice
117

in v o ices
Q A
authenticity of the origin and the No digital signature required. Any
integrity of the content of an invoice given means which will ensure
1.
are ensured? If yes, which specific authenticity and integrity will be
type of digital signature and digital sufficient.
tacitly?
invoices).
4.
have free choice.
118

Q A
invoices. However, to preserve legal
certainty, Spanish law specifically
states that EDI, QES and “recognized
ensured?
signatures” ensure the integrity and
authenticity.
Business controls can be used to

2. establish reliable audit trails linking
invoices and supplies.

deduct input VAT?
5.
text editor etc.).
119
Q A
2.
electronic data?
Is it allowed to store the electronic Electronic invoices may be stored
5. archive in a different EU member abroad, provided that the tax authority
state? is notified and given online access.
10 years, starting at the end of the year
of receipt.
120
Q A
kept up-to-date.
121
SWED EN

3. 
(Art. 226 no. 5)
4. n.a.supplier (and/or service provider) (Art. 226 no. 3) in domestic
transactions
5. n.a.
6. 
(Art. 226 no. 5)
7. n.a.
8. 
11. 
12. 
16. n.a.
EUR) currency
17. 
122

amount
25. n.a.
26. 
27. 
(Art. 226 no. 11a)
28. n.a.
29. n.a.
30.  Remarks on the application of a VAT margin scheme
123

in v o ices
Q A
tacitly?
4.
have free choice.
124

Q A
Electronic signatures and EDI are
numerated, but also any means that
guarantee the authenticity and integrity
ensured?
of the invoice are accepted.

2. No specific rules.
No; the Swedish authorities are not

expected to issue guidance and will not
provide certification of a taxpayer’s
system.
deduct input VAT?
5.
text editor etc.).
125
Q A
2.
electronic data?

No, the originally data-format has to be
maintained.
storage?
Is it allowed to store the electronic Yes, but tax authority must be notified
5. archive in a different EU member (also if the place for archiving the
state? invoices changes).

7. No specific requirements.
7 years, normally starting at the end

of the year of receipt; 10 years for
companies to which the Swedish
accounting act is applicable.
126
Q A
No; accounting material must be stored
in the form it was compiled.
127
SWI T Z ER L A ND

3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. n.a.
8. n.a.
9. n.a.Invoice number (in sequential order) (Art. 226 no. 2)
11. 
12. 
16. n.a.
EUR) currency
17. 
128

amount
24. n.a.supplies, triangulation cases, exports to non-EU countries or any
25. n.a.
26. n.a.
27. n.a.
(Art. 226 no. 11a)
28. n.a.
29. n.a.
129

in v o ices
Q A
Yes, a digital signature with a Swiss or
recognized foreign certificate is
required. However, Swiss VAT
authorities do accept invoices without
a digital signature, if the authenticity
1. and integrity can be proved in another
way and the legal requirements for an
adequate and orderly accounting are
fulfilled. A digital signature remains the
securest method to proof the
authenticity and integrity.
Yes, an approval of the invoice
2. recipient is necessary and can be given
tacitly.
tacitly?
invoices).
Yes, PDF or PDF/A data format are fine
(for issuance as well as for storage). If
May the invoice be issued in a PDF the invoice has been sent with digital a
4.
or PDF/A data format? signature, the signature file has to be
stored as well together with the PDF or
PDF/A file.
have free choice.
130

Q A
The authenticity and integrity can be
proved either with a digital Signature or
in another way if the legal
requirements for an adequate and
orderly accounting are fulfilled. A
ensured?
digital signature remains the securest
method to proof the authenticity and
integrity.
purchase order).
deduct input VAT?
5.
text editor etc.).
131
Q A
2.
electronic data?
that the invoice remains readable, that
the tax authority is given online access
state?
and that tax evaluation remains
possible.
132
Q A
kept up-to-date. A digital signature on
the scanned invoice/file is
recommended.
133
U NI T ED K I NGD OM

3. 
(Art. 226 no. 5)
transactions
5. 
6. 
(Art. 226 no. 5)
7. n.a.
8. 
11. 
12. 
16. n.a.
EUR) currency
17. 
134

23. 
(stating the amount) if not yet included in total amount
25. n.a.
26. n.a.
27. 
(Art. 226 no. 11a)
28. n.a.
29. n.a.
Remarks on the application of a VAT margin scheme; the note
30. 
also has to state which margin scheme is being used
Other remarks:
In case of self-billing, HM Revenue & Customs recommend the
33. 
inclusion of the following statement: "The VAT shown is your
output tax due to HM Revenue & Customs"
135

in v o ices
Q A
Electronic invoicing is subject to
Is electronic invoicing subject to approval of the recipient. This can be
approval of the invoice recipient? If given tacitly. If the recipient does not
2.
yes, can the approval be given wish to receive electronic invoices,
tacitly? they can request paper invoices from
the supplier.
There is no specific data format
requirement. HMRC provide EDI, XML,
Do they have to be in a “structured” comma delimited ASCII and pdf files as
3. data format (such as XML)? If yes, examples of acceptable formats. These
which format is appropriate? are simply examples given by HMRC; it
is up to the supplier what he or she
does.
4.
have free choice.
136

Q A
There is a choice of approaches. This
can (for example) be done through
How can the authenticity of the business internal controls, AES and
1. origin and integrity of the content be QES, or “proper EDI” with an
ensured? interchange agreement based on the
European Commission 1994
Recommendation.
It is entirely up to the taxpayers how
they do this. For example, internal
control procedures with an audit trail
could be implemented: Such as
2. matching of the invoice with existing
purchase order) and authorisation
controls over the processing of the
invoice.
There is no formal requirement to
document. However, the business must
be able to demonstrate the controls in
place.
deduct input VAT?
5.
text editor etc.)
137
Q A
Electronic invoices may be archived in
any format, provided that the
authenticity, integrity and legibility of
the original data can be ensured.
Do electronic invoices have to be any format, provided that the
2.
archived in digital form? authenticity, integrity and legibility of
Yes, it is. From a practical perspective,
it may however be advisable to retain
the invoice in the original format as
electronic data?
well.
any format, provided that the
authenticity, integrity and legibility of
storage?
Is it allowed to store the electronic Invoices can be archived anywhere in
5. archive in a different EU member the world provided that they can be
state? made available to HMRC on request.
No. Electronic invoices may be
Are there any requirements regarding archived in any format, provided that
7.
the archiving system? the authenticity, integrity and legibility
of the original data can be ensured.
6 years, but HMRC may agree to a
shorter time on application.
138
Q A
Is it allowed to scan paper invoices Yes, it is. Other (non VAT) rules may
1. and only keep the scan? If yes, what require that certain documents are kept
are the requirements to do this? in the original paper format.
139
Disclaimer
The information in this handbook is for general guidance only. It is
essential to take professional advice on specific issues and their impact
on any individual or entity. No liability can be accepted for any errors
or omission or for any person acting or refraining from acting on the
information provided in this handbook.
Concept/Design: Peters, Schönberger & Partner mbB, Munich

Peters, Schönberger & Partner mbB
Schackstrasse 2, 80539 Munich
Tel.: +49 89 381720
Internet: www.psp.eu

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Editor Peters, Schönberger & Partner mbB

From a VAT perspective, invoice documents represent a major element of

The European VAT Directive (2006/112/EC) lays down the minimum

Businesses in Europe find themselves in a similar situation with regard to

Philipp Matheis Janneke Speetjens

Conseils Associés SA Paul Grosjean www.cadfk.com +33 140679788

Abante Auditores Jose M. Hinojal www.abanteauditores.com +34 902734200

Concept/Design: Peters, Schönberger & Partner mbB, Munich

United Kingdom 134

1. n.a. Designation as “invoice“

* only under certain conditions

20.  VAT amount must be specified in EUR

2. Sp ecia l r eq u ir em en t s f o r (in com in g a n d ou t go in g) elect r on ic

3. Au t h en t icit y o f t h e o r ig in , in t egr it y of t h e con t en t a n d

20. n.a. VAT amount must be specified in EUR

2. Sp ecia l r eq u ir em en t s f o r (in com in g a n d ou t go in g) elect r on ic

3. Au t h en t icit y o f t h e o r ig in , in t egr it y of t h e con t en t a n d

Is it allowed to convert electronic

Electronic invoices may be stored

1. n.a. Designation as “invoice“

20. n.a. VAT amount must be specified in EUR

2. Sp ecia l r eq u ir em en t s f o r (in com in g a n d ou t go in g) elect r on ic

3. Au t h en t icit y o f t h e o r ig in , in t egr it y of t h e con t en t a n d

Is it allowed to convert electronic

* only under certain conditions

20.  VAT amount must be specified in EUR

2. Sp ecia l r eq u ir em en t s f o r (in com in g a n d ou t go in g) elect r on ic

3. Au t h en t icit y o f t h e o r ig in , in t egr it y of t h e con t en t a n d

All business controls that ensure the

Are there any documentation There is no requirement by law. It is

Are there any requirements regarding VAT commissioner must be informed if

1. n.a. Designation as “invoice“

20. n.a. VAT amount must be specified in EUR

2. Sp ecia l r eq u ir em en t s f o r (in com in g a n d ou t go in g) elect r on ic

3. Au t h en t icit y o f t h e o r ig in , in t egr it y of t h e con t en t a n d

Business controls must ensure a

Are there any documentation

Is it allowed to convert electronic

Invoices may be stored outside the

1. n.a. Designation as “invoice“

* only under certain conditions

20.  VAT amount must be specified in EUR

2. Sp ecia l r eq u ir em en t s f o r (in com in g a n d ou t go in g) elect r on ic

3. Au t h en t icit y o f t h e o r ig in , in t egr it y of t h e con t en t a n d

Which business controls on invoices

Are there any documentation

Is it allowed to convert electronic

Yes; Data must have perfect

If the invoices are archived

6 years from end of the years to which

1. n.a. Designation as “invoice“

20. n.a. VAT amount must be specified in EUR

2. Sp ecia l r eq u ir em en t s f o r (in com in g a n d ou t go in g) elect r on ic

3. Au t h en t icit y o f t h e o r ig in , in t egr it y of t h e con t en t a n d

Is it allowed to convert electronic No; electronic invoices must be

Electronic invoices may be stored

Visual inspection of the electronic

1. n.a. Designation as “invoice“

20. n.a. VAT amount must be specified in EUR

2. Sp ecia l r eq u ir em en t s f o r (in com in g a n d ou t go in g) elect r on ic

3. Au t h en t icit y o f t h e o r ig in , in t egr it y of t h e con t en t a n d

1. n.a. Designation as “invoice“

20.  VAT amount must be specified in EUR