It seems invoices provided through on-line platforms are a future for accounting departments. This solution allows the customer to log on to a dedicated service and download their invoice at any time. However, in practice the solution generates plenty of concerns in terms of its tax implications. For example, what if the customer, in addition to having access to the on-line invoice, receives a paper one at the same time? In the case of a mistake, can we cancel such an invoice and remove it from the system? When we provide invoices parallelly (on paper and via a website), do we issue two different invoices for the same transaction and, hence, become exposed to the risk of “empty invoices” and double VAT counting?
One of our clients implemented an on-line service of exactly this kind and asked us to resolve those concerns. In our opinion, if certain conditions are satisfied, the above risk should not arise and an on-line invoice may be cancelled. The tax authorities had exactly the same view, as evidenced in the tax ruling of 3 February 2022 by the Director of National Revenue Information (ref. 0111-KDIB3-1.4012.934.2021.1.IK), concerning this case.
You will always find it worthwhile to seek expert advice when implementing new billing or accounting solutions. This will help avoid disputes with customers or suppliers and unfavourable tax consequences.