E-Invoicing in Greece

Regarding the e-invoicing requirements in Greece, there have been some recent changes. These include that under the new e-book scheme, taxpayers have several methods to submit their accounting and tax data. One of the options here is to submit the data through a myData-accredited e-invoicing service provider. Although this often involves talk of electronic invoicing, or e-invoicing, this arrangement actually has nothing to do with electronic invoicing.

Accordingly, mandatory e-book reporting is not e-invoicing. This is because e-invoicing refers to the issuance and exchange of invoices in an electronic format. To do this, e-invoices must contain data elements that meet certain legal requirements. This means that e-invoices contain relevant business data that business partners have agreed to in advance.

In contrast, in the e-book scheme in Greece, sellers as well as buyers are required to submit a classification of income and expenses for each item on an invoice based on the VAT regulation. This means that each item on the invoice can be either exempt, assigned 6%, 13% or 24% VAT, etc. Such data is not present in paper or electronic invoices, as these are accounting elements.

Thus, providing this classification and summary is not the same as e-invoicing. Rather, it is a reporting requirement that can be done in several ways. Although the Greek authorities mention e-invoicing in connection with the e-book scheme, it has nothing to do with it.

What data do taxpayers have to report?

In addition to the summary and classification of income and expenses, taxpayers must also report other data not related to invoices. These include accounting entries such as salary slips (wage statements), depreciation and amortization. Such data is generally not included in an invoice or processed by e-invoicing providers. For more information on the exact specifications for e-book reporting, you can also refer to this article by scrolling down further.

Is e-invoicing mandatory?

From this point of view, there is no obligation to issue invoices electronically. The e-book reporting obligation only covers the reporting of accounting data to the myData platform. This means that even if a myData agent is selected to report the bookings, the seller is not under any obligation to actually exchange the e-invoice with the buyer. The seller also does not have to use the selected myData agent to send the e-bill to the buyer. Nevertheless, you can still issue e-invoices in Greece and the e-book scheme does not change any pre-existing e-invoicing obligations in this regard.

So, in summary, the e-book scheme has nothing to do with traditional e-invoicing, and an accredited e-invoicing provider in the context rather describes a method of submitting data to the myData platform. If e-invoicing is indeed the issue in Greece, the new obligations have limited impact on existing regulations and business processes. Thus, taxpayers should be able to continue to use their preferred e-invoicing provider, regardless of whether it is accredited as a myData agent or not.

Our last news article on Greece dealt with the topic of e-invoicing. In recent months, however, a number of things have changed. In particular, the latest decisions A.1138/2020, which were published by the government on June 22, 2020, have resulted in innovations.

The e-book reporting in Greece

In August 2019, the “Independent Authority for Public Revenue” (IAPR) first announced the introduction of the new e-book scheme. Accounting data was to be transmitted to the myDATA platform, which led to further unofficial discussions with various organizations and associations about the exact details of the reporting obligation. The goal here was to be able to create balance sheets for all companies in the country using the myDATA platform by requesting different types of accounting entries, such as:

• Accounting entries to determine annual accounting and tax results.
• Summary of revenue and expense documents for tax purposes
• Classification of expenditure and revenue transactions

The respective income and expenses of the companies are automatically updated in the companies’ e-Books on the myDATA platform and tax returns are also reconciled with the data therein.

All companies that are required to submit their data according to accounting standards are obliged to switch to the e-Book scheme, regardless of the type of company.

Reporting methods

The following methods are approved by the IAPR for reporting to myDATA:

• Business management software, such as accounting software, ERP or government accredited e-invoicing service providers
• myData web portal for manual entry by small businesses, accredited online retail cash registers

Taxpayers must choose a method and not change methods depending on the accounting entry.

Data to be transmitted:

Decision A.1138/2020 also defined the document types and data that must be reported to the myDATA platform.

The following data must be reported by all liable parties:

• Invoices (initial, supplementary and credit) and retail receipts, data from vouchers issued on the basis of special tax regulations, and data on the collection or payment of rent.
• Data from accounting records that form the accounting and tax basis for determining the accounting and tax results for each tax year.
• Accounting records of payroll and depreciation must be submitted separately, while other income/expense accounting entries made at the end of the period may be submitted in their entirety.

The following data must be submitted exclusively by the purchasers:

• Transactions with a foreign non-liable entity, such as imports from third countries and receipt of services
• Revenues from domestic and foreign retail sales
• Transactions related to the sale of electricity and water
• Transactions with credit institutions
• Documents for the payment of social security contributions
• Transactions that should have been reported by the issuer

In each report on revenue and expenditure transactions, the taxpayer must provide a classification of revenue taking into account expenditure. This classification data must be provided for each entry line or at least per VAT type.

Reporting schedule:

If the taxpayer has chosen the method via e-invoicing service provider or ERP, the data must be transmitted in real time before the data exchange between the parties. Exceptionally, the data may also be transmitted within five days after issuance, but must be sent no later than the 20th of the following month after issuance, if the method via ERP was chosen.

In the case of the method via the myData web portal, the reporting operations are carried out by the 20th of the following month after issuance.

Precise timetables for the mandate

• Since July 20, 2020: Voluntary summary of revenue and expenses of data entries processed since July 20, 2020 by e-invoicing providers
• Since July 20, 2020: Optional, classification of revenues and expenditures of data entries processed since July 20, 2020 by e-invoicing providers
• Since October 1, 2020: summary and classification of revenues and expenses of data sent through transmission methods other than e-invoicing providers
• Until December 31, 2020: summary and classification of revenues and expenses in the case of invoicing by self-billing, issued between January 1, 2020 and September 30, 2020, except for data that has already been transmitted
• Until December 31, 2020: payroll entries issued between January 1, 2020 – September 30, 2020
• January 1, 2021 and until February 28, 2021: in particular, the transmission of data by the recipient, in case of non-compliance with the data transmission obligation by the issuer
• Until February 28, 2021: summary and classification of revenues and summary of revenues in the case of self-billing, issued between January 1, 2020 and September 30, 2020, except for data that have already been submitted
• Until March 31, 2021: possibility of acceptance and classification of transactions by issuers