Recently, important decisions have been issued by the Independent Authority for Public Revenue (IAPR) concerning the following issues:

Α. Reduction of tolerance limits of discrepancies in VAT returns

Decision A.1108/2024, of IAPR reduces the limits of the tolerable revenue-expense discrepancies that may exist per VAT return, between the books and the corresponding data transmitted to the digital platform myDATA.

In particular, the tolerable limits of discrepancies are reduced as follows:
a) From 01.07.2024 to 30.09.2024, the revenue declared in the VAT return cannot be less than the revenue transmitted to the myDATA platform by more than 10% and the expenses cannot exceed the revenue transmitted to the myDATA platform by more than 20%.
b) Similarly, from 01.10.2024 to 31.12.2024, there must be no variance in revenue data and only 5% for expense data.
c) From 01.01.2025 onwards, the permissible deviation limits shall cease to exist for both revenue data and expenditure data with respect to the corresponding data transmitted to the myDATA digital platform.

However, the alternative ways of transmitting data remain in force in case of actual difficulties in correcting the amounts of revenue or expenditure with the total sum of outflows and inflows per tax period.

Β. Start of voluntary and mandatory implementation of the Digital Transportation Documents issuance.

The new Decisions A.1122/2024 and A.1123/2024 define the extent of implementation, the two phases and the schedule for the digital monitoring of the movement of goods (digital dispatch note) in real time.

B.1. The procedure

In particular, all enterprises will be required to digitally issue the documents for the movement of goods and transmit the relevant data to the digital platform myDATA of IAPR by receiving the relevant QR Code. The obligation to issue digital transportation documents include domestic and international movements (by road, sea, air, or railway).

The obligation to transmit data to the myDATA digital platform applies to both the consignors and the consignees of the goods in transit as follows:

Consigner
The Consigner of goods has the obligation to issue digitally the transportation documents and transfer their data to the myDATA digital platform before the departure of goods.

Carrier
The Carrier will have the obligation to confirm the receipt of the goods (in Phase B of the implementation). He will also have the obligation to issue a digital transportation document and the corresponding obligation to transmit transportation data to the myDATA digital platform in case he moves goods on behalf of the Consigner or the Third Party Sender, provided that he moves the goods from its own facilities (indicatively 3PL, Transport, Courier).

Consignee
The Consignee confirms receipt of the goods. He is also obliges to transmit transportation data to myDATA digital platform, in case he deals with persons who are not obliged to issue transportation documents, or persons who refuse to issue them or have not issued them by mistake, as well as in case he receives surpluses or deficits.

Decision A 1123/2024 provides more details on the data to be transmitted to myDATA platform (VAT number of the issuer, consignee and other related data), the channels and time of transmission, the types of documents, the purpose of the movement, intra-Community movements, correlations with other documents and complex cases of movements such as transshipments, triangular transactions, issue of a document at a time prior to departure, aggregated consignment notes, etc.

B.2 Implementation by the IAPR

The implementation of the digital monitoring of the transportation of goods will be carried out in two phases:

Phase A includes:

• Documents issuance
• Transfer of transportation data to the myDATA platform and informing the consignee
• Possibility to check the process during the transportation by scanning the QR Code.

Phase B includes:

• Digital monitoring of loads/transshipments
• Receipt of documents and goods by scanning the QR Code of the transportation documents
• Quantity and quality control by the consignee.

B.3. Timetable of implementation

The implementation of the voluntary and mandatory issue and transmission of digital transportation documents by the liable enterprises will be carried out gradually according to the following periods (per Phase and enterprise category):

Phase A of implementation
a) For enterprises with gross revenues of more than 200,000€, as well as enterprises (regardless of the amount of gross revenues), with activities in the sectors of:

• energy products (fuels)
• pharmaceutical products and medical consumables
• building materials
• production, standardisation and trade of olive fruit and olive oil.

Optional application until 30.11.2024 and mandatory application as from 01.12.2024.

b) For other enterprises
Optional application until 31.3.2025 and mandatory application as from 01.04.2025.

Phase B of implementation
For all businesses voluntary application from 01.12.2024 until 31.03.2025 and mandatory application as from 01.04.2025.

B.4 Exceptions

The following persons or transactions are excluded from the application of digital monitoring of the transportation of goods:

• Farmers under the special VAT scheme
• Individuals selling goods or services on an occasional basis (transactions up to 10,000 euros)
• Public or private employees or pensioners who are authors or presenters of educational programs and seminars
• Movements of goods through a continuous flow network (movement of gas, water, gas, electricity and heat)
• Movement of the tools and machinery necessary for carrying out and completing their work by technicians.
• Movement of fixed assets and other movable equipment of any kind, in the event of the transfer of the entity's business establishment

Download the Tax-i in pdf here.