Working Group 3
Storage of Electronic Invoices
                      Heli Salmi

  e-invoicing Public Event - Brussels, 11...
Problems of electronic
                       storage of invoices
Based on the work of CEN/ISSS eInvoice Focus Group
repor...
Problems of electronic
                        storage of invoices
Problems that may occur will be in cross border
transac...
Problems of electronic
                         storage of invoices
Format: In some countries, the invoice data is to be s...
Task 3.1 Quidelines for
                                    storage

To describe rules for storage of electronic invoices ...
Task 3.2 Co-operation with
                      Tax Authorities
In furtherance of the objective of the EC Directive on
In...
Task 3.3. Service Providers
                           Quidelines
To describe rules and guidelines for service providers
D...
Task 3.3 Service Providers
                           Quidelines
A questionnaire for Service Providers
The questionnaire c...
Task 3.1 Quidelines for
                                    storage

Background: Service Providers’ View
      The majorit...
Task 3.1 Quidelines for
                                   storage

Legislation on storage – main rules
National legislati...
Task 3.1 Quidelines for
                                    storage

Electronic Signatures, recommendations
 •     Authent...
Task 3.1 Quidelines for
                                    storage

Questions to the local tax authorities
 •    Period o...
Task 3.1 Quidelines for
                                   storage

Questions to the local tax authorities (continued)
   ...
eInvoicing WS Public Event, Brussels 11 April 2006
Task 3.3. Service Providers
                           Quidelines
Different legislation
Third party service agreement
Inte...
Task 3.3. Service Providers
                           Quidelines
Different legislation, main rules
       The invoice iss...
Task 3.3. Service Providers
                           Quidelines
Conversions
      The need for conversion should be mini...
Task 3.3. Service Providers
                           Quidelines
European e-Invoice Forum, recommendation
      In order ...
eInvoicing WS Public Event, Brussels 11 April 2006
Thank you


                 Questions?

        heli.salmi@elma.net


http://comelec.afnor.fr/cen/wsei

      eInvoicing ...
Directive 2001/115/EC on
     Electronic storage of Invoices

With regard to the electronic storage of invoices for goods
...
Directive 2001/115/EC on
      Electronic storage of Invoices

The authenticity of the origin and integrity of the content...
Directive 2001/115/EC on
      Electronic storage of Invoices

The taxable person may decide the place of storage
provided...
Directive 2001/115/EC on
      Electronic storage of Invoices

Member States may, however, require taxable persons
establi...
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CEN/ISSS Task 3. Storage of Electronic Invoices

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CEN/ISSS Task 3. Storage of Electronic Invoices

  1. 1. Working Group 3 Storage of Electronic Invoices Heli Salmi e-invoicing Public Event - Brussels, 11 April 2006 eInvoicing WS Public Event, Brussels 11 April 2006
  2. 2. Problems of electronic storage of invoices Based on the work of CEN/ISSS eInvoice Focus Group report http://www.cenorm.be/cenorm/businessdomains/businessd omains/isss/activity/einvoice_fg.asp eInvoicing WS Public Event, Brussels 11 April 2006
  3. 3. Problems of electronic storage of invoices Problems that may occur will be in cross border transactions due to differences in the way the Directive is transposed in individual countries Location and access: e.g. multinational corporations who have centralised processing and storage of electronic invoices in another Member State, invoices will have to be stored according to the regulation in the Member State, where the company in question is registered. Duration: the number of years a taxable person has to store invoices varies quite much, from 4 to 10 years (eIFG 2003) If documents have to be stored over a period of seven to ten years, there can easily be one or two technology changes during that period. eInvoicing WS Public Event, Brussels 11 April 2006
  4. 4. Problems of electronic storage of invoices Format: In some countries, the invoice data is to be stored in the form it has been exchanged in, e.g. EDIFACT format, in order to decode the EDI format into clear format it has to be accompanied by the directories Medium of storage: The medium of storage should not be a problem eInvoicing WS Public Event, Brussels 11 April 2006
  5. 5. Task 3.1 Quidelines for storage To describe rules for storage of electronic invoices within the member states, including rules and guidelines for inspection. Deliverable: CWA eInvoicing WS Public Event, Brussels 11 April 2006
  6. 6. Task 3.2 Co-operation with Tax Authorities In furtherance of the objective of the EC Directive on Invoicing, to establish a number of common arrangements governing the use of electronic invoicing, it is recommended that the competent authorities in all EU Member States should consider further opportunities for implementing the Directive in a compatible way, in particular, for cross-border electronic invoicing. Deliverable: Annex to the CWA eInvoicing WS Public Event, Brussels 11 April 2006
  7. 7. Task 3.3. Service Providers Quidelines To describe rules and guidelines for service providers Deliverable: CWA eInvoicing WS Public Event, Brussels 11 April 2006
  8. 8. Task 3.3 Service Providers Quidelines A questionnaire for Service Providers The questionnaire covers the following issues: Background Standards Storage Electronic Signatures Modelling Feedback for recommendations 27 questions 41 answers eInvoicing WS Public Event, Brussels 11 April 2006
  9. 9. Task 3.1 Quidelines for storage Background: Service Providers’ View The majority of the respondents (73%), offer an integrated electronic storage service solution for their customers’ invoices. There appear to be sufficient standards; only 12,8 % of the respondents wished to have more standards for storage. The most consistent comments and wishes for storage centre upon legislation. Respondents hoped that invoice storage, in electronic form only, will be made legal throughout the Member States and that when electronic archiving is in use, no paper documents should be required. eInvoicing WS Public Event, Brussels 11 April 2006
  10. 10. Task 3.1 Quidelines for storage Legislation on storage – main rules National legislations Duration of storage Place of storage Storage in the original form Storage media Storage of coded data Storage of digital signatures Technology change during the storage period Terminating the storage service Annex: Legislation on storage in member states eInvoicing WS Public Event, Brussels 11 April 2006
  11. 11. Task 3.1 Quidelines for storage Electronic Signatures, recommendations • Authentication and integrity have to be guaranteed over the whole storage period of invoices • Electronic invoices have to be stored in a way that the electronic signature stays verifiable over years. • Without the addition of other relevant data, like revocation information, the electronic signature could not be verifiable in the future. • Ensuring stored invoices are long term valid, as specified above, depends on both organisational and technical measures. eInvoicing WS Public Event, Brussels 11 April 2006
  12. 12. Task 3.1 Quidelines for storage Questions to the local tax authorities • Period of storage • Kind of data • Kind of storage: what methods of electronic storage, if any, are not permitted? • Is storage of invoices by 3rd parties allowed? If YES, what special conditions, if any, are imposed? • Is storage of invoices within other EU member states allowed? If YES, what special conditions, if any, are imposed? • Is storage of invoices outside EU member states allowed? If YES, what special conditions, if any, are imposed? eInvoicing WS Public Event, Brussels 11 April 2006
  13. 13. Task 3.1 Quidelines for storage Questions to the local tax authorities (continued) Are there special requirements for indexing or search possibilities? Are there requirements for storage of sum or subtotal amounts (tax codes, invoice total, etc.) for the defined period? Are there additional requirements for storage which have to be fulfilled concerning electronic invoices? eInvoicing WS Public Event, Brussels 11 April 2006
  14. 14. eInvoicing WS Public Event, Brussels 11 April 2006
  15. 15. Task 3.3. Service Providers Quidelines Different legislation Third party service agreement Interconnection agreement between Service Providers Mandatory data on the invoice Conversions between formats Digital signatures Cross-border electronic invoicing Annex: Cases eInvoicing WS Public Event, Brussels 11 April 2006
  16. 16. Task 3.3. Service Providers Quidelines Different legislation, main rules The invoice issuer follows the legislation in his country and the receiver follows the legislation in his country. The invoice issuer and the recipient are always responsible for fulfilling their own national legal requirements for invoicing, even where a third party service is used. eInvoicing WS Public Event, Brussels 11 April 2006
  17. 17. Task 3.3. Service Providers Quidelines Conversions The need for conversion should be minimised wherever possible and conversions restricted to those that are necessary to bridge the differing formats of the message originator and the message end receiver, since repeated conversions may result in loss of data quality, or even loss of data, in the individual messages being converted eInvoicing WS Public Event, Brussels 11 April 2006
  18. 18. Task 3.3. Service Providers Quidelines European e-Invoice Forum, recommendation In order to support the cross-border electronic invoicing between traders in different Member States, an European e-Invoice Forum could be established. eInvoicing WS Public Event, Brussels 11 April 2006
  19. 19. eInvoicing WS Public Event, Brussels 11 April 2006
  20. 20. Thank you Questions? heli.salmi@elma.net http://comelec.afnor.fr/cen/wsei eInvoicing WS Public Event, Brussels 11 April 2006
  21. 21. Directive 2001/115/EC on Electronic storage of Invoices With regard to the electronic storage of invoices for goods or services, any taxable person shall ensure that copies of invoices issued by himself, by his customer or, in his name and on his behalf, by a third party, and all the invoices which he has received are stored. eInvoicing WS Public Event, Brussels 11 April 2006
  22. 22. Directive 2001/115/EC on Electronic storage of Invoices The authenticity of the origin and integrity of the content of the invoices, as well as their readability, must be guaranteed throughout the storage period. The information they contain may not be altered; it must remain legible throughout the aforementioned period. Member States referred may require that invoices be stored in the original form in which they were sent, whether paper or electronic. They may also require that when invoices are stored by electronic means, the data guaranteeing the authenticity of the origin and integrity of the content also be stored. eInvoicing WS Public Event, Brussels 11 April 2006
  23. 23. Directive 2001/115/EC on Electronic storage of Invoices The taxable person may decide the place of storage provided that he makes the invoices or information stored there available without undue delay to the competent authorities. In case the invoices are stored in another Member State; the Member State where the taxable person is registered will have the right to access the data within the limits of the Directive. The Member States may impose specific conditions prohibiting or restricting the storage of invoices in a country with which no legal instrument exists relating to mutual assistance similar in scope to that laid down by the Directives. eInvoicing WS Public Event, Brussels 11 April 2006
  24. 24. Directive 2001/115/EC on Electronic storage of Invoices Member States may, however, require taxable persons established in their territory to notify them of the place of storage, if it is outside their territory. The Member States shall determine the period for which taxable persons must store invoices relating to goods or services supplied in their territory and invoices received by taxable persons established in their territory. eInvoicing WS Public Event, Brussels 11 April 2006
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