The new Circular letter on e-invoicing extensively comments on the concepts of “business controls”. The invoice, whether issued on paper or electronically, is to be considered in the broader context of the business activities performed. The Authorities now explicitly declare that the strict technological means, such as EDI and digital signature, are no longer sufficient to prove the authenticity of a transaction. Instead, alternative evidence resulting from business controls is necessary.
The choice of business controls and how these are implemented is left open to the taxpayer and should be in line with the type of activities, values traded and size of the company. However, the Tax Authorities give clear incentives and suggestions in this respect. Reference is made to some general IT controls, the possibility to contract an external auditor and self-control and documentation.
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