The issue of an e-invoice is mandatory from 1 January 2019. Since then, the legislation has undergone several amendments and updates, the latest of which came into force on 4 May 2020.
The revisions, which mainly aimed at streamlining the procedure for creating the pre-filled VAT return, focused on two specific aspects: changes to the XSD scheme and the introduction of new codes in order to achieve greater accuracy when filling in the document (updates to the XML layout).
XSD schema: what changes?
The most “technical” part of the changes to electronic invoices concerned the XSD Schema. It has the task of regulating the information management methods, through tags and attributes used in the XML programming language (the one with which all electronic invoices must be made according to the law).
These are both formal and substantive changes, mainly related to ordinary, simplified and cross-border invoices. The wording of some information has therefore been changed:
- the ordinary invoice;
- the simplified invoice;
- Invoices issued by cross-border companies;
- the control criteria for errors 00404 and 00409;
- the description of error 00420.
And new control attributes have been introduced:
- controls for invoices with codes 00443, 00444, 00445, 00471, 00472, 00473, 00474;
- checks on invoices with codes 00321, 00325 and 00448.
XML track: the new codes
The upgrade to the XML track, is the one that has greatly simplified the procedure for creating the electronic invoice to VAT holders. The changes have introduced two new codes, in order to identify the type of transaction and document. The nature of the transaction concerns those cases where VAT cannot be applied.
Before the update on 4 May, the cases were divided as follows:
- N1: transactions excluded ex art. 15;
- N2: transactions not subject to VAT;
- N3: non-taxable transactions;
- N4: transactions exempted under Article 10;
- N5: transactions in the margin scheme;
- N6: Reverse Charge transactions;
- N7: VAT paid in another EU country.
Under the new system, more detailed details have been added for some specific cases, in particular the N2 now has two subcategories:
- N2.1: transactions not subject to VAT under articles 7 to 7-septies of Presidential Decree 633/72;
- N2.2: transactions not subject to VAT – other cases.
N3 has six:
- N3.1: non-taxable transactions – exports;
- N3.2: non-taxable transactions – intra-Community supplies;
- N3.3: non-taxable transactions – supplies to San Marino;
- N3.4: transactions treated as export supplies;
- N3.5: non-taxable transactions – following declarations of intent;
- N3.6: non-taxable transactions – other transactions not contributing to the formation of the ceiling.
while N6 has nine:
- N6.1: Reverse Charge – sale of scrap and other recovered materials;
- N6.2: Reverse Charge – sale of gold and pure silver;
- N6.3: Reverse Charge – subcontracting in the construction sector;
- N6.4: Reverse Charge – sale of buildings;
- N6.5: Reverse Charge – sale of mobile phones;
- N6.6: Reverse Charge – sale of electronic products;
- N6.7: Reverse Charge – services in the construction and related sectors;
- N6.8: Reverse Charge – energy sector operations;
- N6.9: Reverse Charge – other cases.
As regards the types of document that can be issued, three have been added to the nine already present, all relating to supplements and self-invoicing for the purchase of goods:
- TD17 – Integration/self-invoicing for the purchase of foreign services;
- TD18 – Integration for the purchase of intra-Community goods;
- TD19 – Purchase of goods ex art. 17 c.2 DPR 633/72.
It should also be noted that on May 4, 2020, the possibility to consult electronic invoices issued from January 1, 2019 until that time also expired. Since the updates came into force, in fact, only invoices that comply with the new format can be found (at the Inland Revenue Archives).