mandatory from May 4, 2020

New Electronic Invoice codes: the new technical specifications, starting from next May 4, 2020, are illustrated by Assonime, in the note of March 4, 2020.

A transitional period starts from 4 May 2020 and will last until 30 September 2020, after which incorrect invoices will be discarded!

The Revenue Agency, with the provision of 28 February 2020, approved the new technical specifications of the xml layout (version 1.6 of annex A), new electronic invoice codes, which replace, with effect from 4 May 2020, the previous technical specifications (version 1.5 referred to in annex A of the provision of the Director of the Revenue Agency n.89757 of 30 April 2018).

The new provision specified that, to ensure the continuity of services and the gradual adaptation to the new specifications, until 30 September 2020, the Exchange System (ES) will accept the electronic invoices prepared according to the previous technical specifications.

Attention to the transition period for the use of the new electronic invoice codes

In essence, therefore, since from 4 May and until 30 September 2020 the Interchange System will accept electronic invoices and variation notes prepared both with the new scheme and with the one currently used (technical specifications version 1.5), only starting from the 1st October 2020 it will become mandatory to send the electronic invoices and the change notes prepared exclusively on the basis of the new approved scheme to the Exchange System (technical specifications version 1.6).

The mandatory use of the new technical specifications of the xml layout also means that, from 1 October, electronic invoices that do not comply with the new layout will be discarded by the Exchange System of the Revenue Agency.

With regard to the content of the new technical specifications version 1.6, it should be noted that the layouts have been modified to make the “TipoDocumento” (TD) and “Natura” (N) codifications more adherent to transactions relevant for VAT purposes.

These innovations will allow, on the one hand, operators to have one greater flexibility in preparing e-bills, and on the other hand, will allow the Revenue Agency to prepare the pre-filled VAT return more precisely.

Current codes (still valid until 30/9/2020)

In this regard, the “NaturaOperazione” field, used in cases where VAT is not applied, currently identifies 7 types of codes:

N1 – Off-field VAT transactions pursuant to Article 15;
N2 – Transactions not subject;
N3 – Non-taxable VAT transactions;
N4 – Exempt operations;
N5 – Transactions subject to margin / VAT not shown on the invoice;
N6 – Transactions subject to reverse charge (for reverse charge operations, in cases of self-billing for purchases outside the EU of services, for some particular imports of goods);
N7 – VAT paid in another EU state (distance sales pursuant to art. 40, paragraphs 3 and 4, and art. 41 paragraph 1, letter b, of decree-law no. 331 of 1993; provision of telecommunication and tele services – broadcasting, as well as services rendered by electronic means pursuant to art.7-sexies, letter feg of the dprn 633 of 1972 and art.74-sexies of the dprn 633 of 1972).

New electronic invoice codes

Now the new measure, to identify the particularities of transactions relevant for VAT purposes, has introduced some detail codes.
The first group of codes relates to transactions not subject to VAT, for which there is still an invoicing obligation pursuant to art. 21, paragraph 6 and 6 bis of the D.p.r. n. 633 of 1972.

Field N2

Specifically, the following codes have been introduced in field N2:

N2.1, with which the operations listed in articles 7 to 7-septies of the Presidential Decree will be identified n. 633 of 1972;
N2.2, with which all other operations not subject to the application of the tax will be identified.

Field N3

As for the VAT non-taxable transactions (field N3) which contribute to the determination of the ceiling, the following codes have been introduced:

N3.1 – exports;
N3.2 – intra-community transfers;
N3.3 – sales to San Marino;
N3.4 – operations assimilated to export sales;
N3.5 – non-taxable operations following declarations of intent;
N3.6 – other operations that do not contribute to the formation of the ceiling.

Field N6

Finally, also in relation to operations subject to reverse charge, the introduction of the following codes is reported:

N6.1 – transfer of scrap and other recycled materials;
N6.2 – supply of gold and pure silver;
N6.3 – subcontracting services in the construction sector;
N6.4 – sale of buildings;
N6.5 – sale of cell phones;
N6.6 – sale of electronic products;
N6.7 – services rendered in the construction sector and related sectors;
N6.8 – operations carried out in the energy sector;
N6.9 – other cases.

From 1st October 2020 those who do not update will be rejected

It should be borne in mind that, starting from 1 October 2020, if the operator does not indicate one of the specific codes on the invoice (for example, for ordinary invoices it will no longer be sufficient to use only the codes N2, N3 or N6), the system will discard the invoice with error code 00445 (for cross-border invoices the error code is, instead, 00448).

“Document Type” codes between old and new

The provision of 28 February last provided for several changes also with reference to the “TipoDocumento” codes, which, before the changes introduced by the same, were the following:

TD01 Invoice;
TD04 Credit note;
TD05 Debit note;
TD07 Simplified invoice;
TD08 Simplified Credit Note;
TD10 Invoice for intra-community purchase of goods;
TD11 Invoice for the purchase of intra-community services;
TD12 Summary document (art.6, c. 1 of Presidential Decree no. 695 of 1996);
TD20 Self-billing for regularization and integration of invoices (art.6, paragraph 8, legislative decree n.471 of 1997 or art.46, c.5, of decree-law n.331 of 1993).

The new encodings of the types of documents that operators can use in an optional way from 4 May until 30 September 2020 and will have to use, however, compulsorily starting from 1 October next, are as follows:

TD16 Internal reverse charge invoice integration (for additions that are optionally sent to the ES by the recipient of an reverse charge invoice limited to cases of internal reverse charge);
TD17 Integration / self-billing for the purchase of services from abroad,
TD18 Integration for the purchase of intra-community goods,
TD19 Integration / self-billing for the purchase of goods pursuant to art.17, c.2, of the Presidential Decree n. 633 of 1972 (with the use of these codes the operator can avoid transmitting the esterometer for foreign passive invoices both EU and Extra EU);
TD21 Self-billing for stripping;
TD22 Extraction of goods from VAT custody, TD23 Extraction of goods from VAT custody with payment of VAT (with the use of these codes, the operator can manage the operations relating to extraction from the VAT custody, see, in this regard, circular 14 / E / 2019);
TD24 Deferred invoice pursuant to art.21, paragraph 4, lett. a) (for deferred invoices linked to DDT for goods and suitable proof of performance for the provision of services);
TD25 Deferred invoice pursuant to art.21, paragraph 4, third sentence, lett. b) (for internal triangular operations);
TD26 Sale of depreciable assets and for internal transfers (for the operations referred to in art. 36 of Presidential Decree no. 633 of 1972);
TD27 Invoice for self-consumption or for free transfers without recourse.

Lastly, the provision postponed the deadline set for the transferee / client final consumer to 4 May 2020 in order to join the consultation and acquisition service for invoices and their electronic duplicates (term originally introduced by point 8 ter of the Director’s provision 89757 of the Revenue Agency of 30 April 2018).

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March 5, 2020

Vincenzo D’Andò

This information is taken from the Daily Diary published every day on CommercialistaTelematico