Italy SDI e-invoice update

The Italian tax office has provided further guidance on the 1 January 2019 extension of the Sistema di Interscambio (SdI) e-invoice reporting to B2C and B2B transactions.  This new obligation will require all resident businesses to submit compliant e-invoices to the government’s SdI platform for automatic approval and forwarding onto customers.

The following clarifications were provided:

• Resident businesses must submit to the SdI platofrm e-invoices for supplies to non-resident businesses. They will not need to include the ‘recipient code’, instead marking zero’s as for B2C invoices. The non-resident customer will be able to retrieve their approved PDF purchase invoices from the SdI platform, or the vendor can provide them. Although the latter would not guarantee a compliant purchase invoice for input VAT deduction.
• The free government e-invoice storage facility will be effective for 15 years
• Purchase e-invoices received after the month end, but dated in the prior month, may be deducted in the prior month up until 15^th of the month received (the day before the prior month VAT return submission deadline)
• There is no requirement to give e-invoices unique numbers aside from their regular VAT invoice numbers
• For domestic reverse charge invoices with the N6 code, the purchaser will use the approved SdI invoice, but will also create a self-invoice. This may (but not mandatory) be submitted to SdI.
• The Italian Data Protection Authority has raised EU General Data Protection Regulation concerns, and requested a delay in the SdI 2019 modifications.