Tax authorities globally continue to update e-invoicing requirements

These new systems aims to encourage business growth through digitalization while also closing the VAT gap.


From 18 April 2020, all public authorities in Denmark will be required to accept e-invoices over the PEPPOL European network and the PEPPOL BIS 3 format. PEPPOL is a secure, interoperable e-delivery network that connects e-procurement systems of the various EU countries through accredited Access Points. Access Points are responsible for sending and receiving files in line with PEPPOL-established standards.

Denmark is one of the furthest ahead EU countries when it comes to e-invoicing. Since 2005, public institutions and their suppliers have been required to use the NemHandel platform for e-invoicing.

To meet Directive 2014/55/EU requirements, the NemHandel will be connected to the PEPPOL network. All public services will be able to receive invoices in PEPPOL BIS 3 format & in OIOUBL format.


From 1 April 2020, all public organisations and private companies have the right to request their suppliers provide them with an electronic invoice in a format that is compliant with European and Finnish standards.

The law does not prohibit anyone from receiving invoices in different formats, but the buyer now has the right to reject electronic invoices that do not contain the data fields in the Directive 2019/55/EU. The law also maintains that all private traders and public procurement entities must have the ability to send e-invoices that comply with the European Standard, if asked.

Historically, Finland has been successful when it comes to e-invoicing. The State Treasury website claims that 92% of invoices exchanged today with the central government are electronic.


In February 2020, the Italian Revenue Agency approved new technical specification rules for e-invoicing for businesses. The rules include a new XML requirement for FatturaPA that will be mandatory in 2021. Public administration will be rejecting e-invoices that are not compliant with the updated version of the technical specifications.

E-invoices can be submitted under the current technical specifications (v. 1.5) until 31 December 2020. From 1 October 2020, SDI will accept e-invoices prepared with the new scheme and with the current technical specifications.

Codes will be imperative to the setup of the XML files and the codes will indicate the type of document and the nature of the transaction.

Seven new document types have been introduced, and taxpayers will be required to identify the correct document type among 18 different codes. In addition, seven new transaction types have been introduced to identify the nature of transactions, and taxpayers will need to identify the right transaction type among 24 transaction types.


E-invoicing was introduced in Turkey in 2012. It has been announced that from 1 July 2020, companies with gross annual turnover of TRY 5 million or more in 2018 or 2019 are obliged to use the e-invoice system.

Taxpayers that meet these requirements in 2020 and beyond should switch to the e-invoicing system at the beginning of the seventh month of the following accounting year.

Below are some of the businesses are required to switch to e-invoices regardless of their turnover:

  • Companies that are licensed by the Turkish Energy Market Regulatory Authority;
  • Vegetable and fruit traders;
  • Online service providers facilitating online trade

Turkey continues to tackle the VAT gap by implementing these changes.


Electronic invoices have been used by businesses in Vietnam since 2011. Following Decree No. 51/2010/ND-CP and Decree No. 04/2014/ND-CP, e-invoicing will be mandatory. Beginning 1 November 2020, businesses operating in Vietnam must issue e-invoices following not only the rules established by the law but also in compliance with the technical parameters required by the General Department of Taxation (GDT). The legislation permits two types of e-invoices: e-invoices with tax verification codes and e-invoices without tax verification codes.

Verification codes can only be obtained by sending invoice data to the GTD prior to sending the invoice to the buyer.

Various factors that determine which process businesses must adhere to:

E-invoices with verification codes

These e-invoices require a unique code that is issued by the tax authority before a business or individual selling goods or providing services can send it to the buyer. This means the invoice data must be sent to the GDT to obtain the code to be included on the valid e-invoice. This will be mandatory for:

  • Businesses that are operating in forestry, fishery agriculture and construction with more than 10 employees and an annual turnover greater than VND 3 billion;
  • Self-employed individuals;
  • Individuals and businesses in the trade and service industry with an annual revenue of at least VND 10 billion;
  • “High tax risk enterprises.” This is defined as having equity of less than VND 15 billion and meeting condition i or ii below. High tax risk enterprises must submit e-invoices with verification codes for 12 consecutive months. After this, the business will be reassessed.
    • Enterprises that have been penalised for breaches in invoice rules in the last year;
    • The registered business address has changed twice or more within a 12-month period, without the business making a prescribed declaration or failing to declare and pay tax at the new registration place according to regulations

E-invoices without verification codes

  • Industries not mentioned above can issue e-invoices without verification codes that are not eligible for tax declarations. E-invoice data elements must be sent to tax authorities directly or through an authorised e-invoicing service provider.

Businesses should use e-invoice XML format, containing two components: e-invoice business data and mandatory digital signature data.

All businesses need to be prepared to submit e-invoices for clearance to the General Department of Taxation (GDT) before they will be considered valid for tax purposes. This new system aims to encourage business growth through digitalisation and close the VAT gap.

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