Collective invoices - how to use them from 2014?

Service-Tax

The possibility of issuing collective invoices for services other than continuous, as well as for deliveries of goods appeared at the beginning of 2013, along with the amendment to the Ordinance of the Minister of Finance on tax refunds to certain taxpayers, invoicing, method of storing them and the list of goods and services to which goods and services tax exemptions do not apply. However, the regulations that will come into force on 1 January 2014 do not explicitly include the option of using collective invoices. Does it mean going back to the old rules?

Collective invoices in 2013

Before 2013, entrepreneurs were required to separately document each transaction carried out. The only exception were continuous services, such as rental or advertising services. This rule was a burden in situations where a large number of invoices were issued for one contractor in one period.

In order to ease entrepreneurs, the amended regulation of the Minister of Finance on, inter alia, preparing invoices, par. 9 sec. 3, according to which the invoice may document several separate deliveries of goods or services made during a month, if it is issued no later than the last day of the month in which the goods were issued or the service was performed.

Therefore, even in a situation where in one month an entrepreneur carried out a large number of transactions with a given contractor, he did not have to document each of them with a separate document. All settlements could be included in one collective invoice issued by the end of a specific month.

Collective invoices after changes from 2014

As of 1 January 2014, the aforementioned ordinance of the Minister of Finance on issuing invoices will cease to apply. Provisions relevant to taxpayers in this respect will be implemented in the Value Added Tax Act.

With the change, the provision on the possibility of issuing collective invoices will disappear from the regulations. Fortunately for entrepreneurs who have already got used to the convenience of these documents, the lack of such direct indication does not exclude the possibility of documenting a larger number of economic events with one invoice.

Pursuant to Art. 106i paragraph. 1 of the VAT Act, from the beginning of 2014, the taxpayer will have a significantly longer time to issue an invoice. Apart from a few exceptions specified in the act, the invoice should be issued no later than on the 15th day of the month following the month in which the goods were delivered or the service was performed. Therefore, starting from January next year, the entrepreneur will be able to issue a separate invoice for each sale, or to include all transactions from one month on one collective document, issued at the latest by the 15th day of the month after the month in which the transactions were made.

Example:

The entrepreneur sells goods to his contractor several times a month - on January 5, and then on January 12, 23 and 31. So far, he could document each of these transactions with a separate invoice, issued no later than 7 days from the delivery of goods (i.e. - January 12, 19, 30 January and 7 February, respectively), or include the entire monthly sale to this contractor on one collective invoice issued no later than on the last day of the month - January 31st.

Currently, the entrepreneur also has a choice - he can document the sale with a separate invoice for each transaction, but he can also include all of them in one document. However, no matter which option they choose, they will have time to issue an invoice until the 15th of the month after the month in which the sale took place - that is, by February 15.

To sum up - entrepreneurs who use collective invoices in their business do not have to be afraid of the upcoming amendment. What's more, changes in the dates of issuing invoices further extend the period that the entrepreneur has to issue such a collective document - from the last day of the current month until the 15th day of the following month.