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ConnectingEurope / eInvoicing-EN16931

Validation artefacts for the European eInvoicing standard EN 16931
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Allow code 106 (Withheld taxes and social security contributions) on Allowance code list 5189 #382

Open AndreasPvd opened 5 months ago

AndreasPvd commented 5 months ago

Some European Member states added a special kind of tax handling during the last few years. Those taxes are not added to the invoice amount, but withheld instead. They exist, for instance, in Romania for sale of waste on in Germany as a construction withholding tax.

Those kinds of taxes need to be shown in BG-20 (Document allowances) as the amount is withheld by the invoicer. Currently, the code list does not support the appropriate code.

Please allow code 106 with the next code list update.

The code can be found here: https://service.unece.org/trade/untdid/d23a/tred/tred5189.htm

Br, Andreas

midran commented 2 months ago

Code list 5189 is implemented as a subset. The content of the subset is determined by CEN/TC434 so first this needs be raised there.

SimonsPaul commented 1 month ago

The EN itself did not restrict this codelist. At is (re)published by the Advisory Group (but not maintained. The A.G. can add it for the next release if there is consensus in the A.G.

Just as a sidenote to reflect on:

  1. Be aware however that Witholding Tax is out of scope for the EN16931-1.
  2. Is adding code 106 sufficient fur supporting the requirement. Experience learns that other data elements are needed like extra bank account numbers, amount of withholding tax to be paid, paymentterms etc.
SimonsPaul commented 1 month ago

I sent a request to the A.G. to discuss the topic in the next meeting.

midran commented 1 month ago

It is correct that the EN16931 itself does not restrict code list 5189 but neither does the Technical Advisory Group, TAG (EC/DIGITAL). The restrictions are decided by CEN TC/434-WG1.

The listing of full codes is maintained by EC/DIGITAL (TAG) by following the "Annex A, Instructions between TC434 and CEF on listing of EN 16931 code list" that was created by TC/434 and last updated in 2021 when codes were added to the subset of invoice type codes from 1001. Fred Bloomstein probably has the best knowledge of that document.

In order to change the 5189 subset, e.g. to add 106, it is enough to change this document and file it as a change request to the EC/DIGITAL service desk. The request will then be addressed in a TAG meeting before adoption. The deadline for change requests into the next code list publication is last week of February.

AndreasPvd commented 1 month ago

Thx. This is why I made the request in June 2024 because the deadline for Codelist version 14 was August 2024. So I expected to have an update in version 14...

midran commented 1 month ago

@AndreasPvd challenge is that first TC/434 needs to update this Annex A.

SimonsPaul commented 1 month ago

I have informed Fred Van Blommestein and asked to undertake the necessary action.