Greek e-books and e-invoices myDATA

The Greek tax office, AADE, is planning to mandate the implementation of the myDATA electronic platform for taxpayers from 1 July 2021. This would create a standardised e-book schema, supplemented with 'e-invoices', with monthly automated submissions. These direct digital filing requirements will be adopted for VAT, corporate income tax and withholding taxes.

Note - whilst termed e-invoicing by the Greek authorities, this model is actually closer to transaction reporting seen in Spain's SII and other EU countries recently. There is no Greek requirement to send e-invoices to the customer; only to report transaction details to the tax office.

The new timetable for submitting electronic VAT information to AADE is below. For 2021, date may be transmitted within 5 days of the issuance on mandated invoice, but at latest by the 20th of the month following.

E-invoices by businesses

• 20 Oct 2020 for businesses producing e-invoices via certified outsourced invoicing agents
• 1 July 2021 for businesses producing e-invoices via their accounting / ERP systems or manually

Retail sector reporting

• 1 Jan 2021 transaction data for businesses not obliged to use the approved cash registers

Accounting e-ledgers

• 1 Oct 2020 purchase ledger data reporting going forward
• 31 Dec 2020 sales ledger data for the whole of 2020.
• 28 Feb 2021 purchase ledgers date for 1 Jan to 30 Sep 2020.

• e-invoices: Sales VAT invoices (domestic B2B transactions). Plus records of purchase e-invoice that have been received. Invoices details must include accounting code details - unlike regular e-invoices.
• e-Books: accounting General Ledger transactions; cash ledger payroll; and Fixed asset transactions, include depreciation provisions. B2C and cross-border transactions, not included in e-invoice data, will be added to the e-books.

The above digital records will be transmitted automatically to the AADE, via the myDATA portal. The filing deadline is set to the 20th day of the following month.

Taxpayers have four options to submit their e-invoices and e-books:

1. Manual uploads for small numbers of invoices;
2. From enabled ERP’s and accounting software linked to myDATA;
3. Online certified cash registers which are connected to AADE; or
4. Commercial providers of e-Invoicing services. These must be Greek-resident businesses.

AADE anticipates being able to match and validate taxpayers VAT transactions with their counterparties' submissions to detect errors and fraud. This will be done live via myDATA, and discrepancies will be immediately returned via myDATA.

The plans will include electronic cash registers for retailers. For businesses without electronic accounting systems, there will be a manual upload option.

The Greek tax authorities will produce two sets of accounting records for each filing taxpayer from the above information:

• Detailed Books
• Summary Books

The Greek government certifies electronic invoice service providers. Only certified providers may issue B2C or B2C e-invoices on behalf of taxpayers, and then transmitting the data to the tax authorities myDATA REST API in the approved invoice format. They may also transmit the invoice data to customers.

Providers must have demonstrated robust invoice creation, storage and retrieval systems to guarantee the integrity of invoices. They must also be Greek resident, and meet financial stability tests. Invoice data may be stored elsewhere in the EU.

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