Staying Updated. January Tax Technology Newsletter. In this issue e-invoicing e-archive e-bookkeeping e-record Keeping Requirements Trends

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1 Staying Updated Tax Technology Newsletter Dear Sir/Madam, In this issue e-invoicing We are now in an important milestone for Electronic Transformation in Turkey. Approximately companies are now using and will be preparing their first electronic ledgers and submit the respective summary approval documents in the following months. In the final sprint to comply with this legislation, it is fundamental that companies ensure that their electronic ledgers not only pass the schematron validation and other technical controls but, most importantly, that its content is in line with Tax Procedural Law. Our PwC Tax Technology Team has developed tools and methodology to control your ledgers before submission In this second issue of our Newsletter, we share not only the most recent developments and updates with regards to e-transformation, but also provide insight on the current trends and hot topics in the market. Kind regards, Cenk Ulu Partner Indirect Tax Services 1

2 Have you completed the neccessary year-end adjustments to your system? Resetting of serial number Serial number of the s shall be updated to 2015, and the first issued in 2015 shall start from 1. Accordingly, the first to be issued in 2015 should for example be in xxx format. Invoice rejection Invoices which are not rejected within 8 days shall be deemed as accepted, in line with Turkish Commercial Code. In this regard, the rejection of s in integration, special integration and portal method should be done within 8 days. Tax Authorities have requested special integrators to set up locks that prevent sending rejection application responses after the 8 days have been exceeded. Year-end invoices The issue date of the invoice is stored along with the date of the invoice in the system logs of the application. Tax Procedural law sets that invoices shall be issued within seven days of the delivery of goods or services. Accordingly, the latest date to issue invoices dated 31 December 2014 is 7. Invoice Issuing Period In the portal method, when trying to issue invoices whose respective delivery note date is more than 7 days prior, the system gives an error and does not allow it to be issued. Although this technical restriction does not apply to the integration and special integration methods, it is of importance to comply with the 7 days restriction set forth by the Tax Procedural Law in order to avoid future criticism from the Tax authorities. 2

3 Are you aware of the format requirements for storing your e- Archive Invoices? Application Through its publication on the Official Gazette dated 30 December 2014, Communiqué no. 443 came into force amending Communiqué no Through these amendments, provided that an invoice is issued in accordance with the formats and standards and a printable version of the invoice is attached to the.xml version, in cases where the customer requests it, it will be possible to deliver the invoice through electronic means. In this case, it is not required to print out the invoice. Consequently, in case agreed by the recipient, it will no longer be obligatory to print out the invoices issued to taxpayers that are not registered to the application. On the other hand, please keep in mind that it is still required to deliver a paper print out of the invoices issued to real persons and taxpayers that are not registered for the application if requested. Furthermore, invoices issued to taxpayers that are not registered for e-invoicing application are to be kept and submitted in accordance to the respective delivery format. Electronic Invoice Recording System In addition to amendments to the application, it has been set forth that companies within the scope of Electronic Invoice Recording System (Elektronik Fatura Kayıt Sistemi) will be expected to adjust their systems to become compliant with the provisions of the aforementioned Communiqué at a date to be announced by the Revenue Administration no later than 1 April

4 Obligation to use invoices will come into effect as of 1 January Are you aware of the advantages this application will bring to companies? E-Archive Invoice Signature: With the recent updates on the guidelines, electronic signature format required on electronic documents has been changed from XADES-A (archive) to XADES-BES (basic). This technical change will be effective on the invoice signing performance and its time requirement. With the previous signature format, integrator or special integrator companies were supposed to get a proofed time stamp from TUBITAK for each invoice and this operation could require minutes (or even longer) if there was a system bottleneck. The switch to basic electronic signature allows local signing (i.e. it is no more required to ask for a time stamp from TUBITAK servers). This ease on e-archive invoice creation will allow companies to generate legally valid invoices and use a print-out of it as a delivery note simultaneously. Please keep in mind that verbal discussions with special integrators and authorities point that this relief might be for a temporary period and could be returned to its original format. NGCRD information on Report New Generation Cash Register Devices (NGCRD) receipt information is removed from the report requirements. Therefore, retail companies will no longer require a data feedback from such devices. Recent Live Companies A small number of companies have recently gone live in application and a few more are expected to go live in the near future. Their experiences and feedbacks to both market and administration will soon enhance the practical knowledge of the application in the market. 4

5 Web Service Updates Web Service Guideline for e-ledger summary approval file (aka as berat file) submissions have been updated with more details and explanations last week. Previously, it was claimed by some e-ledger user companies that the web services of the administration were not functioning properly. This failure was creating major problems for those generating hundreds of berat files due to its respective ledger sizes. Important Notice for New Joiners Following our advice in the previous newsletter, we would like to mention important areas for the transition to eledger again. Please keep in mind that berat files shall be uploaded to the system of the Administration until the last day of the third following month (last month of the accounting period shall be submitted until the last day of Corporate Income Tax return). However, it is of importance to create the electronic ledgers in compliance with legislation from the first day. Furthermore, the three month granted for the approval period is only applicable to the fiscal stamping and uploading of the summary files and does not provide extension to the already existent 10 and/or 45 day recording rule set forth by the Tax Procedural Law. 5

6 Changes have been set forth to the Electronic Record Keeping Requirements Tax Procedural Law Circular no. 70 was published in order to shed light on the Record Keeping Requirements set forth by Tax Procedural Law General Communiqué no Scope of records to be kept It is sufficient for taxpayers that are within the scope of the application, but do not conduct the transactions specified in the Communiqué as their primary operations, to only create and store the records electronically with regards to related transactions. Scope of the period The effective date of the Communiqué has been re-determined to be 1 Janıary 2015 through the publication of Tax Procedural Law General Communiqué No In this regard, submission of the minimum record keeping contents by taxpayers within the scope may not be requested in such a way that it includes periods prior to the effective date of the Communiqué. Format of the data It is sufficient for taxpayers that are obliged to comply with record keeping requirements to store the records attached to the Communiqué in electronic media. Due to the fact that there have been no specifications of format, technical obligation or form obligation with regards to creation of records electronically, taxpayers may use their current ERP solutions or accounting programs in order to comply with the provisions of the Communiqué. In this regard, electronic table programs with open source coding or database management systems may also be used. Format of reports The.xml,.xls,.xlsx,.txt,.csv formats specified in the Communiqué are file formats that may be used for submission of the records when requested, furthermore, it is sufficient for the records to be able to be submitted in one of the mentioned formats. Rules governing the submission of the records. 6

7 Latest market trends in e- Transformation in Turkey Lately, we have been observing a trend to switch from integration to special integration methods in application. system seems to have matured and used without many problems. As mentioned in our last issue, Revenue Administration has published Draft Communiqués on its website. In case these Communiqués come into force unchanged, there will be further penal sanctions with regards to abuse of information obtained by third party special integrators for e-invoicing purposes As known, the deadline for obligated parties to switch to application is also fast approaching. In order to benefit from the integration method in application, many ISO certificates are required. In this regard, we expect similar requirements to be required for integrating the system of the taxpayers with the system of the Revenue Administration in the future. Acquiring all the certificates may prove difficult and time consuming, hence, we expect the general tendency in the market to continue towards contracting special integration vendors. We would like to remind you that the availability and permission to use special integrators does not remove the ultimate responsibility of the taxpayers to keep and submit their records. Thus, companies should especially evaluate the safety of their and Invoice archives and arrange a work flow such as obtaining secondary archives from the special integrators in specified intervals in order to have a back up archive in their own servers. 7

8 Staying Updated Tax Technology Newsletter Cenk Ulu Parter Indirect Tax Services Tel: +90 (212) PwC Turkey The Indirect Tax team of PwC Turkey is the largest in the country with approximately 70 experienced professional staff and is currently providing tax advisory services to more than 700 companies. We are also the largest professional consulting firm in Turkey, in terms of the scope and quality of services provided. Combining local knowledge with international expertise enables our team to provide its clients with the highest possible level of service. PwC Turkey, operating since 1981, consists of five offices in Istanbul (2), Ankara, Izmir and Bursa. Cem Aracı Director Indirect Tax Services Tel: +90 (212) PwC Tax Technology Team PwC Tax Technology Team provides assistance and support with regards to tax implications during the implementation process of the newly introduced electronic applications. Hande Turkyılmaz Senior Manager Indirect Tax Services Tel: +90 (212)