E-invoicing mandate

E-invoicing is enjoying increased momentum in South America, and Paraguay is rapidly following the lead of its neighbouring countries with developments in the e-invoicing terrain. 

Companies that are on a ‘designated list’ shared by the tax authorities will be obligated to use e-invoicing by 2 January 2023. 

Further company lists will form the basis for each phased period, of which there will be 10 stages, found here. The final phase is expected in October 2024.  

E-invoicing in Paraguay shares key characteristics with other Latin American states, including the requirement to use an XML format, as well as the obligation for a digital signature.  

e-Transport system

Tungsten Network has recently published an overview of the key characteristics of the e-Transport system in Romania. The system was developed to monitor the transport of goods specifically with high fiscal risk, with the underlying aim of preventing tax fraud. On 1st October 2022, importers and experts will need to oblige with the e-Transport system requirements, should they wish to avoid incurring any financial penalties.  

The obligation to declare the goods commenced earlier, on 1st July 2022, although sanctions and fines because of non-compliance will only come into effect from 1 October 2022. 

Update on B2B e-invoicing

Belgium has shifted the timeframes for B2B implementation in line with the following: 

  • 1 July 2024: mandatory e-invoicing for businesses with an annual turnover of more than 9 million 
  • 1 January 2025: mandatory e-invoicing for small and medium businesses  
  • 1 July 2025: all other taxpayers 

Member States require approval from the European Union to mandate e-invoicing. This is currently pending.  

As previously stated, it is expected that Belgium will favour the PEPPOL e-invoicing model, in sharp contrast to recent mandates in Poland and Italy.  

Government encourages the adoption of PEPPOL e-invoicing 

Australia has mandated business-to-government (B2G) e-Invoicing since July 2022, requiring government agencies to adopt the use of PEPPOL e-Invoicing. Further on, the Australia Taxation Office (ATO) announced a Business e-Invoicing Right (BER) initiative to promote business-to-business (B2B) e-invoicing in a gradual phase, starting with large companies from July 2023. Under  this initiative, businesses are legally obliged to adopt and send einvoices if requested by their customers. This means that Australia is not implementing a government-led e-Invoicing mandate (aka as Continuous Transaction Control), but rather seeks to stimulate the  uptake of e-Invoicing through ‘market dynamics’.  

The ATO remains committed to encouraging the adoption of e-invoicing, and recently published an article on the benefits of PEPPOL e-invoicing for SMEs. With more than 18,000 businesses already using eInvoicing, the government expects a significant growth in the use of e-invoicing over the next 12 months.  

Renewed plans for mandatory e-invoicing

The Dominican Republic had previously set out guidelines for mandatory e-invoicing in 2019- but these were not adopted at the time.

The Dominican Republic’s General Directorate of Internal Taxes (Direccion General de Impuestos Internos (DGII) has now again issued fresh guidelines with the aim of delivering e-mandatory e-invoicing in the country. This appears to have been triggered by the e-invoicing trajectory which has been accelerating in neighbouring Latin American countries.

The DGII favours a phased implementation of the e-invoicing mandate, in line with the following:

  • 2023: large companies
  • 2024: medium-sized companies
  • 2025: small enterprises

E-invoicing has been voluntary in the Dominican Republic since 2019.

New e-invoicing mandate

Guatemala is the latest country to welcome mandatory e-invoicing, following the lead of neighbouring countries in Latin America.

From 1st July 2022, all VAT-registered taxpayers in Guatemala must use an e-invoicing tool to issue their invoices electronically. All VAT taxpayers will be obligated to use the Factura Electronica en Linea (FEL) portal to register e-invoices.

The FEL portal facilitates invoice issuance, electronic signatures, invoice transmission to buyers and archiving.

Electronic invoices can be generated using an online tool provided by the tax administration or through an authorised service provider.

A list of authorised certifiers can be found via the following link:


New e-invoicing requirements

In a fast-paced month for e-invoicing developments in South America, Brazilian tax authorities have announced plans for a new partial e-invoicing mandate which will require certain taxpayers to issue e-invoices via a government portal from 1st January 2023.

From 1st January 2023, individual micro-entrepreneurs (MEI) issuing invoices e-invoices for services not subject to the Interstate Sales Tax (ICMS) are obligated to issue e-invoices.

E-invoicing for supplies to individuals remains optional.

Tungsten Network will continue to monitor e-invoicing developments in Brazil as we await further details relating to the mandate.

E-invoicing mandate delay

Panama has delayed the obligation to submit invoices via the national e-invoicing system, the Sistema de Facturacion Electronica de Panama (SFEP).

Resolution No 201-5215, dated 19 July 2022 in Official Gazette No. 29585, dated 25 July 2022, delays the obligation for government suppliers to issue invoices electronically via the SFEP.

An earlier resolution had implied that government suppliers must issue invoices electronically via SFEP. However, this requirement has been delayed to 31 October 2022.

Partial e-invoicing mandate

There has been recent e-invoicing traction across Latin America as companies push to advance the e-invoicing agenda in their respective countries.

Ecuador is the latest country to introduce e-invoicing to its shores.

The Internal Revenue Service (SRI) is introducing mandatory e-invoicing for certain taxpayers by 30 November 2022.

Further to Resolution NAC-DGERCGC22-00000024, any taxpayers subject to income tax that were not obliged to issue invoices electronically must now comply with e-invoicing regulations by 30 November 2022 at the latest.

Ecuador’s e-invoicing history dates to 2012, and the country has since advocated a phased implementation of e-invoicing obligations for taxpayers.

Partial B2G mandate

Greece currently does not have a Business-to-Business (B2B) e-invoicing mandate, although in the Business-to-Government terrain, Directive 2014/55/EU made it mandatory for the central government to receive e-invoices from private sector suppliers.

However, there has been recent clarification from the Greek tax authorities, the Independent Authority for Public Revenue (IAPR) which has shifted some of the e-invoicing obligations to Greek suppliers.

This clarification provides that suppliers who have elected to use Electronic Data Provider Services and have submitted the Declaration of Excusive Data Issuance through a Provider must issue e-invoices. In effect, this imposes a partial B2G mandate on select suppliers.

Obligatory e-invoicing between Italy and San Marino

From 1st July 2022, supplies of goods and services between Italy and San Marino will be subject to mandatory e-invoicing. Up to this point, e-invoicing was optional between the two countries.

The mandatory e-invoicing will be facilitated via the Sistema di Interscambio (SdI).

The San Marino tax office will validate invoices received via the SdI and, if compliant, transmit these to San Marino customers.

There will be some changes required to the XML submitted to the SdI to accommodate supplies to San Marino, including changes to the Codici Destinario, as invoices may now be directed to the San Marino Tax Office.

Tungsten Network can assist with transactions relating to supplies of goods and services to San Marino.

Extension of e-invoicing mandate scope

Italy has extended the scope of taxpayers subject to mandatory e-invoicing in line with the following:

  • 1st July 2022: E-invoicing is mandatory for all businesses exceeding a turnover of 25,000 in the preceding year
  • 1st January 2024: E-invoicing is mandatory for remaining businesses.

Tungsten Network implemented the e-invoicing solution to facilitate domestic transactions in Italy via the Sistema di Interscambio (SdI) in January 2019.

Delay for certified software usage

We have recently communicated on the e-invoicing landscape in Spain following some traction relating to the same in the country- which impacts both the invoice content itself, as well as Business-to-Business (B2B) transactions specifically.

Spain has now announced that the creation of the legal artefact in Spain via certified software- also referred to as verifiable invoicing systems (VERI*FACTU) and used for the creation and submission of invoices- will now be delayed to 1 July 2024. The date was moved following a public consultation.

From 1st July 2024 there will also be voluntary submission of invoices to the Agencia Tributaria- sistemas y programos informaticos o electronicos (SIF).

The proposed rules only apply to resident businesses.

The proposed e-invoicing mandate in Spain is ambitious, with several complexities. Tungsten Network is closely monitoring the e-invoicing curvature in Spain and assessing our position regarding the certified billing software once more detailed information around the same is available.

E-invoicing public test operation

We recently communicated that the e-invoicing mandate was delayed in Slovakia. However, that has not prevented the Slovakian Tax Authorities from establishing a framework to ensure the proposed upcoming e-invoicing roll-out is smooth, efficient and automated, resulting in a more user-friendly and less cumbersome tax solution for taxpayers.

To this effect, the Slovakian authorities have initiated a public testing phase for the proposed e-invoicing solution.

Entities and individuals subject to the testing phase will work with an online application or integration through OpenAPI set up by the tax authority.

It is hoped that the public interaction with the e-invoicing model and its systems will provide valuable insights and underline any necessary required enhancements before the roll-out of the mandate. It also serves to underscore the growing tendency across Europe to involve the general public as an integral part of e-invoicing development process.

B2G e-invoicing delay for small / medium enterprises

Further to Law Decree 42-A/2022, dated 30 June 2022, the proposed extension of the B2G mandate to small / medium enterprises (SMEs) has once again been delayed and is now expected to be implemented on 1st January 2023.

This is synonymous with the further extension of PDFs being accepted as an e-invoice until 1st January 2023, underlining the Portuguese Tax Authorities’ intention to consolidate and expand the scope of their fiscal measures.