E-invoicing, deposits on PET bottles and two-way electronic communication with the Financial Administration
19/11/21
Tax and Legal Alert, November 2021, Issue 4
Reporting of invoice data to the Financial Administration
A draft of an act on invoicing and reporting data to the e-invoice system is to be submitted for comment procedure within the next few days. The new law would introduce an obligation to report structured invoice data from input and output invoices to the Financial Administration on a real-time basis and would take effect from 2023.
The e-invoicing system is intended to assist in preventing tax fraud and increase the efficiency of tax collection. The currently used control statement (similar to SAF-T) is not sufficient in this respect, as it is only submitted by VAT payers, moreover with a time delay after the issuing of an invoice. The e-invoicing system would eliminate these limitations, as data would be reported on a real-time basis, before the invoice is sent to the customer.
All entrepreneurs would have an obligation to report data, regardless of whether they are registered for VAT, with only minor exceptions (e.g. sales recorded in the e-kasa register). Entrepreneurs would be obliged to report invoice data to the Financial Administration before an invoice is issued. Reporting would be undertaken using company accounting software, or a free online application. The Financial Administration would verify the data and send a QR code back to the supplier, to be added to the invoice. After this process is completed, the invoice can be sent to the customer.
The reporting obligation would also affect customers. Customers would have to send data from received invoices before VAT deduction / claiming a tax-deductible expense for CIT purposes.
In the event of a breach of obligations laid down by the law, a penalty could be imposed of up to EUR 10,000.
What does this mean?
If the act is approved, entrepreneurs will have a new obligation related to real-time reporting of data from input and output invoices. In this respect, it will be necessary to adjust accounting software, or set up internal processes for data reporting..
Deposit on PET bottles and cans
From 1 January 2022, a deposit system for bottles and cans will be introduced in Slovakia. This system is intended to increase waste recycling and improve the environment. The deposit system is regulated by Act No. 309/2019 Coll. on deposits on disposable beverage packaging and by Act No. 70/2015 Coll. on waste. The deposit system will be managed by a dedicated non-profit organization the Správca zálohového systému (“Administrator”).
Disposable beverage PET bottles and metal cans with a volume of 0.1 - 3 litres will be included in the deposit system. The system will cover beverages containing at least 80% water (i.e. sweetened beverages, mineral water, fruit juices, energy drinks, beer, and fruit wine). Milk and liquor packaging are excluded from the deposit system. The deposit will be EUR 0.15 for each item of packaging, for all sizes.
Companies selling products in packaging subject to the deposit system will be obliged to register their packaging in the Administrator’s register system and pay a deposit for this packaging. The supply of beverages in disposable packaging must be invoiced with the deposit, which, however, is not as a rule included in the tax base for VAT purposes. The deposit payment will pass from the manufacturer via the distributor to the final customer, who will receive the deposit back after returning the packaging. It will be possible to return the packaging to collection points, which must be set up by retail stores with a sales area of more than 300 m2. The collection of packaging will be undertaken by the Administrator.
What does this mean?
Implementing the deposit system will bring new obligations requiring correct set-up of accounting and invoicing software and cash registers. New obligations will mainly affect companies that manufacture or import packaging, beverages in PET bottles and cans to Slovakia, or otherwise introduce them onto the market, as well as the companies that sell such beverages for final consumption.
Two-way electronic communication with the Financial Administration
From 1 January 2022 there will be a change in communication with the Financial Administration. Communication between the Financial Administration and taxpayers will be completely electronic, not only from the taxpayer to the Financial Administration. The main goal is simplification and making communication more effective.
The implementing of two-way electronic communication on tax issues means that entities will no longer receive letters from the Financial Administration in paper form, or via the Financial Administration´s portal. Official decisions and documents will be sent to eboxes at slovensko.sk, i.e. the central public administration portal. Entities can set up e-mail or SMS notification on receipt of new messages. Two-way electronic communication has already been implemented for excise duties.
If the ebox is not activated for electronic communication (for individuals, etc.), documents from the Financial Administration will still be delivered to the taxpayer in paper form via post.
What does this mean?
If an entity´s ebox on the portal, slovensko.sk, is activated for electronic communication (this should be done automatically for all legal entities registered in the Commercial Register of the Slovak Republic), from 1 January 2022 decisions and official documents will only be delivered electronically to eboxes. We recommend checking the activation of your ebox and validating your login details. Otherwise, there is a risk that the communication from the Financial Administration will be missed.
Subscribe to our PwC Newsletters
