Current Issues
Tax Technology Newsletter
Dear Sir/Madame,
December 2014
Topics
Last days to switch to e-Ledgers
PwC Turkey e-Ledger Validator Tool
e-Invoice UBL TR 1.2
As known, e-Transformation in tax, that is highly prioritized by the Revenue
Administration recently, is in all our agendas. Many companies have switched to
e-Invoicing very recently and currently we are in the last few days to switch to eBookkeeping. Additionally, applications such as e-Archive, New Generation
Cash Register Devices, Record Keeping Requirements are at our doorstep.
In all these applications, as PwC Tax Technology Team, we follow recent
developments closely and try to share them with you promptly. At the same
time, we believe that it will be beneficial to present these developments to you in
a monthly newsletter.
In the first issue of our Newsletter, we will be sharing the recent developments
and updated and our comments with regards to e-Transformation in tax.
Our e-Archive Experiences
Record Keeping Requirements
Draft Communiqués
Kind regards,
Cenk Ulu
Partner
Indirect Tax Services
December 2014
1
Topics
Last days to switch to e-Ledgers
PwC Turkey e-Ledger Validator Tool
e-Invoice UBL TR 1.2
Our e-Archive Experiences
Record Keeping Requirements
Draft Communiqués
•
Platform
Independent
Solutions: e-Invoice solutions obtain
permission
from
the
Revenue
Administration as per the accounting
program it will acquire data from.
Companies that will use a solution that
has not obtained permission for the ERP
it will acquire data from have to use
solutions that have obtained «Platform
Independent» permission
•
Essential information on eLedgers: There are many important
issues in transition to e-Ledgers both
operation and data quality wise that
companies should pay attention to.
Please find below some of such issues;
•
Pre-printed document number and
date
•
E-Invoice number for e-Invoices
•
Journal entries that are recorded in
bulk
•
Document Type definitions
•
Customs and import expenses
•
Employee expenses
•
Journal entry numbers
•
Up to
Information
•
date-ness
Automatic entries
of
•
Transition
periods
for
eLedgers: e-Ledger summary files shall
be uploaded to the system of the
Administration until the last day of the
three month following the month they
refer to. (Last month of the accounting
period shall be approved with fiscal
stamp until the last day of the month that
Corporate Income Tax is due.) However,
it is of importance to create the ledgers in
compliance with legislation from the first
day that the ledgers have begun to be kept
electronically. 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
Applying to the e-Bookkeeping
application on the last week of
December may cause the
system to overload as we
experienced in e-Invoice
application. We recommend
taxpayers that will start
keeping electronic ledgers in
January to apply before the
last week of December in order
to avoid problems.
MERSIS
December 2014
2
Topics
Last days to switch to e-Ledgers
PwC Turkey e-Ledger Validator Tool
e-Invoice UBL TR 1.2
Our e-Archive Experiences
Record Keeping Requirements
Draft Communiqués
PwC e-Ledger Validator Tool is a
pre-control tool. It conducts test
with regards to technical and
format specified in Tax
Procedural Law however does
not validate the accuracy of the
records.
XML
e-Ledger
data
RA
SCHEMATRON
CONTROLS
Tool
PwC
eLedger
Validator
As per the provisions of Tax Procedural
Law General Communiqué No 421,
general ledgers and journals ledgers are
to be kept in accordance with the related
e-Ledger XBRL-GL Guides and in order
for these documents to be accepted as eLedgers, they should be stamped with
fiscal stamp or qualified electronic
certificate and the summary approval file
should be created with a solution that has
obtained permission from the Revenue
Administration. With the PwC «eLedger Validator Tool» that has been
developed by PwC Turkey Indirect Tax
team, compliance of the data created with
the standards and formats specified in
Guides can be examined before the
summary files are uploaded to the system
of the authority.
RA TECHNICAL
GUIDEL
CONTROLS
PwC TPC
CONTROLS
e-Ledgers
with correc
t format
PwC
Control
Report
These controls include;
•
Syntax controls of the XML files that
have been created (Well Formedness
Test),
•
Creation of data in accordance with
XBRL GL taxonomy (Validation
Test),
•
Subjecting
to
determined
by
Administration,
•
Seperation
of
e-Ledger
files,
signature and consistency control of
the journal and general ledgers,
•
Consistancy controls of the e-Ledger
that has been created and the ERP
data,
•
Controls with regards to summary
file information,
the
the
controls
Revenue
Additionally, compliance with form
priciples set forth by Tax Procedural Law
will be examined by our team.
We will convey our findings as a result of
the aforementioned tests in the form of a
report along with our comments to our
Clients before the stage in which the the
ledgers are signed and transfered to the
system of the authority.
December 2014
3
Topics
Last days to switch to e-Ledgers
PwC Turkey e-Ledger Validator Tool
e-Invoice UBL TR 1.2
Our e-Archive Experiences
Record Keeping Requirements
Draft Communiqués
In the previous version, 35 main titles
could be used in an e-Invoice. Through
the UBL TR 1.2 that has been developed
in accordance with UBL 2.1 standard, this
number has been increased to 44. While
in the previous versions only 35 main
headers were able to be used, in the UBL
TR 1.2 version that was developed in
accordance with the UBL 2.1 standard,
this number was increased to 44.
Additionally, through new sub headers
that it is now possible to enter data into
thousands of different fields.
UBL TR 1.2 update may be used in test
media as of December 1, 2014.
Some of the newly added fields are as
follows;
As of today, the prinicples with
regards to UBL TR 1.2 standards
have been published as draft,
therefore after an examination of
the new version if companies
determine that they may require
additional updates, it will be
possible to convey such
information to the Revenue
Administration and request
improvements.
•
Cost center information
•
Other documents related to the
invoice information
•
Third party supplier or customer
information that is not the recipient
or issuer of the invoice,
•
Tax processes responsible (ex. Sworn
Financial Advisor)
•
Delivery
information
alternative target etc.)
•
Withheld tax information
(carrier,
Besides these, it has also been made
possible to enter additional information
to hundreds of new fields that have been
made avaialable.
December 2014
4
Topics
Last days to switch to e-Ledgers
PwC Turkey e-Ledger Validator Tool
e-Invoice UBL TR 1.2
Our e-Archive Experiences
Record Keeping Requirements
Draft Communiqués
Due to the fact that e-Archive
application has not entered the
agendas of many companies yet,
there hasn’t been pressing
concern with regards to solution
developments by providers and
legislative updates recently.
Due to the fact that e-Archive application
has not entered the agendas of many
companies yet, there hasn’t been pressing
concern with regards to solution
developments by providers and legislative
updates recently.
The biggest advantage to this application
is the fact that through the current
structure of the application, invoices to be
issued be issued to parties that are not
registered to e-Invoice application will
also be issued in electronic media and
archived in electronic format.
Furthermore, in retail sales, in order for
the invoice to be used as delivery note, it
is required to be issued at the time of sale
. Accordingly, issuing and stamping of the
inovices is evaluated as an interruption
especially for companies with many
stores in the retail sector when
considering the delivery time of goods.
Consequently, a different structuring is
required especially in order to speed up
the process in retail sector. It seems like it
will be more easily adaptable for sectors
other than retail sector.
However, it only seems possible for
suppliers in service sector to completely
issue invoices electronically to real
persons. On the other hand, delivery of
invoices on paper will not be eliminated
for operations such as retail that include
the delivery of goods.
December 2014
5
Topics
Last days to switch to e-Ledgers
PwC Turkey e-Ledger Validator Tool
e-Invoice UBL TR 1.2
Our e-Archive Experiences
Record Keeping Requirements
Draft Communiqués
Record
Keeping
Requirements
Communiqué that was previously to come
into force in July was postponed to come
into force on January 1, 2015. As of the
effective date;
Taxpayers in the scope of the List (I) of
Special Consumption Tax (SCT)
Even though not in the scope of SCT,
Those holding one of these licenses: retail
dealership, transportation, distribution,
storage, mineral oil, free user, bunker fuel
delivery, transfer, oil refinery ownership
and processing licenses in scope of PML,
Those holding at least one of these
licenses: CNG, storage, total sales,
delivery, transfer, import and export
licenses in scope of Natural Gas Market
Law,
Those holding at least one of these
licenses:
distribution,
storage,
transportation and autogas retail dealer
in scope of Liquefied Petroleum Gas
(LPG) Law
•
Sales,
•
Export
•
Purchases
•
Manufacturing
•
Import
•
Other
As per goods included in Schedule B of
List (III) of SCT Law,
•
Inventory with regards to period end
and period beginnning stocks
Real and legal persons who have an
authorization license regarding Tobacco
During the studies we conducted with
many companies since the publication of
the communique, we have observed that
most of the infromation required within
the scope of this communiqué is stored in
different places such as the ERP, Customs
broker, legal books, and on printed
documents. We have observed that in
order to gather all the information to to
archive
compliance
with
the
requirements
set
forth
by
this
communiqué, a detailed study needs to be
conducted.
Commerce Certification from Tobacco
and Alcohol Market Regulatory Authority
Real and legal persons who have an
authorization
license
regarding
Production and Operation Convenience
Certification from Tobacco and Alcohol
Market Regulatory Authority ,
Real and legal persons who conduct sales
and marketing activities of products to
real and legal persons who have an
authorization
license
regarding
Production and Operation Convenience
Certification form Tobacco and Alcohol
Market
Regulatory
Authority
to
Wholesale Certification owners
Shall keep the following records in such
way that they include the details that have
been specified in the annex of the
communiqué
and keep them in
electronic format and submit them when
requested in electronic format
Furthermore, we have observed that
although it is not their main area of
operation, due to their importing
activities, many companies fall within the
scope of SCT and consequently are in the
scope of Electronic Record Keeping
Requirements.
December 2014
6
Topics
Last days to switch to e-Ledgers
PwC Turkey e-Ledger Validator Tool
e-Invoice UBL TR 1.2
Our e-Archive Experiences
Record Keeping Requirements
Draft Communiqués
Through the draft Communiqués that have
been published on December 12, 2014,
amendments to e-Invoice, e-Archive and eBookkeeping application has been planned.
Please find below some of the major
provisions that will be set forth in case the
Communiqués are published as is;
Scope extension for e-Invoice and eLedger application: In addition to
taxpayers obliged through Tax Procedural
Law General Communiqué No 421 the
following taxpayers are obliged to switch to
e-Invoice and e-Bookkeeping applications
as of 01/01/2016;
a) Taxpayers with gross sales revenue for
2013 of 10 Million TL and more,
b) Taxpayers who obtain mineral oil license
within the scope of the 5015 Petroleum
Market Law after the date of publication of
Tax Procedural Law General Communiqué
No. 421 and Taxpayers that produce or
import the goods stated in the list No. (III)
attached to the Special Consumption Tax
Law.
Additionally, those that obtain mineral oil
license within the scope of the 5015
Petroleum Market Law and Taxpayers that
start to produce or import the goods stated
in the list No. (III) attached to the Special
Consumption Tax Law after the publication
of this communiqué and those that reach 10
Million gross sales revenue after the
calendar year of 2013, are obliged to switch
to using e-Ledgers and e-Invoices as of the
beginning of the following calendar year
that they have obtained the license,
obtained taxpayer status or reached the 10
Million gross revenue provided that they do
not have a preparation period of less than 3
months has been detmirned.
Third Party Information Security:
In order to prevent third party information
sharing by taxpayers that have obtained
special integration permissions within the
scope of e-Invoice and e-Bookkeeping and
taxpayers that have obtained storage
permissions within the scope of e-Invoice,
it has been forseen to include penal
sanctions with regards to this issue to
related communiqués.
Integration
Mehtod
and
Penal
Sanctions:
In
addition
to
the
abovementioned,
in
the
e-Invoice
application,
Of parties that integrate their IT systems,
those that do not keep their systems in a
24/7 continously running state that enables
sending and receiving invoices, excluding
force majeure reasons, their integration
permissions may be cancelled and in case it
is, their portal accounts will automatically
be activated. However, taxpayers are free to
benefit from the e-Invoice application
through special integration method.
Sending of e-Archive Invoices to
parties that are not registered for eInvoice application in electronic
format: Within the scope of e-Archive
application, it is essential to deliver eArchieve invoices to parties that are not
registered for e-Invoice application in paper
format. On the other hand, provided that
the invoice is issued in accordance with eInvoice format and standard published on
www.efatura.gov.tr website, and the
printable view of the invoice is attached, in
accordance with the wishes of the recipient
of the invoice, said invoice may be delivered
in electronic format.
Customs Processes: It’s been stated that
issuance of a new Guide is planned in order
to be able to issue goods with passenger
export invoices as e-Invoices.
December 2014
7
Current Issues
Tax Technology Newsletter
PwC Turkey
Cenk Ulu
Parter
Indirect Tax Services
Tel: +90 (212) 326 6424
[email protected]
Cem Aracı
Director
Indirect Tax Services
Tel: +90 (212) 326 6916
[email protected]
The Indirect Tax team of PwC Turkey is the largest in the country with over 60
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.
PwC Tax Technology Team
PwC Tax Technology Team provides assistance and support with regards to
important issues and tax implications during the implementation process of the
newly introduced electronic applications.
Hande Turkyılmaz
Senior Manager
Indirect Tax Services
Tel: +90 (212) 326 6914
[email protected]
December 2014
8