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openaccountants/skills/cross-border-invoicing-compliance.md

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1---
2name: cross-border-invoicing-compliance
3description: >
4 Cross-border invoicing rules — which country's requirements apply, what goes on the invoice,
5 and how to handle e-invoicing mandates. Use when the user asks about: cross-border invoice,
6 invoicing foreign client, reverse charge invoice, multi-currency invoice, self-billing
7 cross-border, credit note cross-border, e-invoicing cross-border, which invoicing rules apply,
8 Article 219a, supplier country invoicing, Italy SDI foreign, India IRN cross-border,
9 Mexico CFDI foreign, invoice retention cross-border, archiving invoices, ECB exchange rate,
10 VAT currency conversion, recipient-created invoice, or any question about the correct format,
11 content, or process for invoices crossing borders.
12version: 1.0
13jurisdiction: INTL
14tax_year: 2025-2026
15category: cross-border
16---
17 
18# Cross-Border Invoicing Compliance
19 
20> **Disclaimer:** This skill provides general guidance on cross-border invoicing rules. Invoice requirements are jurisdiction-specific and evolving rapidly due to e-invoicing mandates. Consult a qualified advisor before relying on this information for compliance.
21 
22---
23 
24## Skill Metadata
25 
26| Field | Value |
27|-------|-------|
28| Jurisdiction | Multi-jurisdiction (EU, UK, US, India, Italy, Mexico, and general principles) |
29| Primary Legislation | EU: VAT Directive 2006/112/EC, Articles 217–240; Art 219a (invoicing rules applicable); ViDA Directive (phased 2028–2035) |
30| Scope | Invoice format, content, currency, e-invoicing, and archiving requirements for cross-border transactions |
31| Contributor | OpenAccountants |
32| Validation Date | May 2026 |
33| Skill Version | 1.0 |
34| Cross-references | `eu-reverse-charge.md`, `vat-place-of-supply-master.md`, `eu-oss-digital.md`, country-specific e-invoicing skills |
35 
36---
37 
38## Section 1: General Principle — Whose Rules Govern the Invoice?
39 
40### The Basic Rule — Article 219a(1) [T1]
41 
42**Invoicing follows the rules of the Member State where the supply is deemed to take place** (i.e., the place-of-supply country).
43 
44### The Exceptions — Article 219a(2) [T1]
45 
46| Exception | When It Applies | Whose Rules |
47|-----------|----------------|-------------|
48| **(a) Reverse charge — supplier not established in supply country** | B2B intra-EU services where customer self-assesses VAT (Art 196) | **Supplier's** country sets the invoicing rules |
49| **(b) Supply outside the EU** | Services deemed supplied outside the EU | **Supplier's** country sets the invoicing rules |
50| **Self-billing under reverse charge** | Customer issues the invoice on behalf of the supplier | Place-of-supply country's rules apply (basic rule) |
51| **Non-EU supplier making taxable supplies in EU** | Non-EU seller with EU-taxable transactions | Place-of-supply country's rules always apply (no exception) |
52 
53### Practical Impact [T1]
54 
55| Scenario | Whose Invoicing Rules? |
56|----------|----------------------|
57| German consultant invoices French company (B2B reverse charge) | **Germany** (supplier's rules — exception (a)) |
58| French company sells goods domestically | **France** (place of supply = France) |
59| Italian company invoices US client for consulting | **Italy** (supply outside EU — exception (b)) |
60| US company sells SaaS to French consumer via non-Union OSS | **France** (place of supply = France; non-EU supplier — no exception) |
61| Dutch company issues self-billing invoice for services received from Malta under reverse charge | **Netherlands** (self-billing under reverse charge = basic rule) |
62 
63---
64 
65## Section 2: EU Cross-Border Invoicing (Intra-EU B2B)
66 
67### Mandatory Invoice Content for Intra-EU B2B Under Reverse Charge [T1]
68 
69**Legislation:** VAT Directive Art 226.
70 
71Every VAT invoice in the EU must include these elements. For reverse charge invoices, additional requirements apply:
72 
73| Element | Requirement |
74|---------|-------------|
75| Invoice number | Sequential, unique |
76| Date of issue | Date the invoice is created |
77| Date of supply | Date the service was performed or goods delivered (if different from issue date) |
78| Supplier identification | Full name, address, VAT identification number |
79| Customer identification | Full name, address, **VAT identification number** (verified via VIES) |
80| Description | Nature and quantity of goods supplied or extent and nature of services |
81| Taxable amount | Net amount in the agreed currency |
82| VAT rate | N/A for reverse charge (0%) |
83| VAT amount | EUR 0.00 or blank |
84| **Reverse charge notation** | **Mandatory.** Must state "Reverse charge" or equivalent in the relevant language |
85| Reference to legislation | "Article 196, Council Directive 2006/112/EC" or national equivalent |
86 
87### Reverse Charge Notation by Country [T1]
88 
89| Country | Notation |
90|---------|----------|
91| English | "Reverse charge — Article 196, Council Directive 2006/112/EC" |
92| German | "Steuerschuldnerschaft des Leistungsempfängers — § 13b UStG" |
93| French | "Autoliquidation — Article 196, Directive 2006/112/CE" |
94| Italian | "Inversione contabile — Art. 196, Direttiva 2006/112/CE" |
95| Spanish | "Inversión del sujeto pasivo — Artículo 196, Directiva 2006/112/CE" |
96| Dutch | "BTW verlegd — Artikel 196, Richtlijn 2006/112/EG" |
97| Portuguese | "Autoliquidação — Artigo 196.º, Diretiva 2006/112/CE" |
98 
99### Time Limits for Issuing Invoices [T1]
100 
101The VAT Directive requires invoices to be issued by the **15th of the month following** the month in which the supply took place (Art 222). Individual member states may impose shorter deadlines.
102 
103| Country | Deadline |
104|---------|----------|
105| Germany | Immediately, but no later than 6 months after supply (§14 UStG) |
106| France | By the 15th of the following month |
107| Italy | By the 15th of the following month (12th for immediate invoices) |
108| Spain | By the 15th of the following month |
109| Netherlands | Before the 15th of the following month |
110| Belgium | By the 15th of the following month |
111 
112---
113 
114## Section 3: Reverse Charge Invoice Requirements
115 
116### What Changes on the Invoice When Reverse Charge Applies [T1]
117 
118| Normal Invoice | Reverse Charge Invoice |
119|---------------|----------------------|
120| Shows VAT rate (e.g., 19%) | Shows 0% or no VAT line |
121| Shows VAT amount (e.g., EUR 950) | Shows EUR 0.00 or omits VAT amount |
122| No special notation needed | **Must include reverse charge notation** |
123| Only supplier's VAT number required | **Both** supplier and customer VAT numbers required |
124| Customer pays gross amount | Customer pays net amount only |
125 
126### Customer's Obligations Upon Receiving a Reverse Charge Invoice [T1]
127 
1281. **Self-assess output VAT** at local rate on the net amount
1292. **Claim input VAT** on the same return (if entitled — fully taxable business)
1303. Both entries must appear on the VAT return (see `eu-reverse-charge.md` for box mappings)
1314. Report on Intrastat / acquisition reporting if required by the member state
132 
133### Common Mistakes [T1]
134 
135| Mistake | Consequence |
136|---------|------------|
137| Supplier charges domestic VAT instead of reverse charge | Customer pays VAT they shouldn't. Double taxation risk if customer also self-assesses. Supplier must issue credit note. |
138| Missing reverse charge notation | Invoice does not meet legal requirements. Customer's tax authority may deny input VAT deduction. |
139| Customer's VAT number not on invoice | Cannot prove B2B nature. Tax authority may reclassify as B2C. |
140| Supplier doesn't verify VAT number via VIES | If number is invalid, reverse charge does not apply. Supplier liable for domestic VAT. |
141 
142---
143 
144## Section 4: Multi-Currency Invoicing
145 
146### Which Currency for VAT Calculation? [T1]
147 
148| Jurisdiction | Rule |
149|-------------|------|
150| **EU (VAT Directive Art 230)** | VAT amount must be expressed in the currency of the Member State where the supply takes place. If invoiced in a foreign currency, convert using ECB rate or national customs rate. |
151| **ECB exchange rate** | Use the rate on the **date of the chargeable event** (typically date of supply). Alternatively, some member states accept the rate on the date of invoice. |
152| **UK** | HMRC accepts the rate at the date of supply. Use HMRC, ECB, or a reputable financial source. |
153| **US** | No VAT — but for sales tax, use the exchange rate on the date of transaction. |
154 
155### Practical Guidance for Multi-Currency Invoices [T1]
156 
157| Element | Best Practice |
158|---------|--------------|
159| Invoice currency | Invoice in whatever currency the contract specifies (USD, GBP, EUR, etc.) |
160| VAT amount | Convert to the local currency using the applicable exchange rate |
161| Exchange rate source | ECB daily rate (EU), HMRC rate (UK), Federal Reserve rate (US) |
162| Document the rate | State the exchange rate and source on the invoice or in your records |
163| Consistency | Use the same exchange rate source consistently — switching sources can trigger audit queries |
164 
165### OSS Returns and Currency [T1]
166 
167| Scheme | Currency Required |
168|--------|------------------|
169| Union OSS / Non-Union OSS | EUR. If your MSI doesn't use EUR, convert at ECB rate on the last day of the quarter. |
170| IOSS | EUR |
171| Domestic VAT return | Local currency of the member state |
172 
173---
174 
175## Section 5: Self-Billing / Recipient-Created Invoices Cross-Border
176 
177### What Is Self-Billing? [T1]
178 
179Self-billing (or recipient-created tax invoice) is where the **customer** issues the invoice on behalf of the supplier. This is permitted under Art 224 of the VAT Directive, subject to conditions.
180 
181### Conditions for Self-Billing [T1]
182 
183| Condition | Requirement |
184|-----------|-------------|
185| Prior agreement | Supplier and customer must have a **written agreement** that the customer will issue invoices on the supplier's behalf |
186| Acceptance procedure | There must be a mechanism for the supplier to accept or reject each invoice |
187| Invoicing rules | Follow the rules of the **place-of-supply** country (Art 219a basic rule applies to self-billing under reverse charge) |
188 
189### Cross-Border Self-Billing [T2]
190 
191| Scenario | Whose Rules? |
192|----------|-------------|
193| Dutch customer self-bills for services received from Italian supplier (reverse charge) | **Netherlands** (place of supply = Netherlands; self-billing under reverse charge follows basic rule, not supplier's rules) |
194| US customer self-bills for services from German supplier | **Germany** (supply outside EU — exception (b) — supplier's rules) |
195 
196### Common Use Cases
197 
198- Large retailers issuing invoices to many small suppliers
199- Royalty payments where recipient calculates the amount
200- Commission arrangements where the principal issues invoices to agents
201 
202---
203 
204## Section 6: Credit Notes and Corrections Cross-Border
205 
206### When to Issue a Credit Note [T1]
207 
208| Trigger | Action |
209|---------|--------|
210| Price reduction after supply | Issue credit note referencing original invoice |
211| Return of goods | Issue credit note for returned items |
212| Invoice error (wrong amount, wrong VAT) | Issue credit note + new corrected invoice |
213| Retrospective discount (e.g., volume rebate) | Issue credit note at end of period |
214 
215### Credit Note Requirements (EU) [T1]
216 
217**Legislation:** VAT Directive Art 219.
218 
219| Element | Requirement |
220|---------|-------------|
221| Format | "Any document or message that amends and refers specifically and unambiguously to the initial invoice" |
222| Reference | Must cite the original invoice number and date |
223| Content | Corrected amounts, including VAT adjustments |
224| Reverse charge credit notes | Same reverse charge notation as original. Customer must reverse their self-assessment. |
225 
226### Cross-Border Credit Note Complications [T2]
227 
228| Issue | Guidance |
229|-------|---------|
230| Different reporting periods | Credit note may fall in a different quarter from the original invoice. Report in the period the credit note is issued. |
231| OSS corrections | Corrections to previous OSS quarters are made on the **next** regular quarterly return (not by amending the original). |
232| Currency differences | If exchange rate has changed since the original invoice, use the rate at the date of the credit note for the adjustment. |
233| Customer in a different country has already filed | Customer must adjust their VAT return in the period the credit note is received. |
234 
235---
236 
237## Section 7: Country-Specific E-Invoicing Quirks
238 
239### Italy — SDI (Sistema di Interscambio) [T1]
240 
241| Element | Rule |
242|---------|------|
243| Mandate | All Italian-established businesses must issue e-invoices via SDI (since 2019 for domestic; since July 2022 for cross-border) |
244| Cross-border sales | Italian businesses must submit an XML e-invoice to SDI even when invoicing foreign customers. The Esterometro was abolished in 2022; replaced by SDI reporting. |
245| Format | FatturaPA XML format. SDI validates the invoice before forwarding. |
246| Foreign supplier selling to Italy | Not required to use SDI (unless established in Italy). The Italian buyer self-assesses VAT and reports via SDI using document types TD17–TD19. |
247| 2026 update | SDI technical specs v1.9.1 effective May 15, 2026. New validation checks (error 00327 for VAT Groups). |
248| ViDA impact | EU ViDA Directive will require alignment with EN16931 standard. Italy's SdI clearance model may need adaptation by 2035. |
249 
250### India — IRN (Invoice Reference Number) [T1]
251 
252| Element | Rule |
253|---------|------|
254| Mandate | E-invoicing mandatory for businesses with turnover ≥₹5 crore (since August 2023) |
255| Cross-border exports | Export invoices must also be reported to the Invoice Registration Portal (IRP) and receive an IRN. Tax invoice must include QR code. |
256| Format | JSON schema submitted to IRP. IRP validates, generates IRN + QR code, digitally signs. |
257| Foreign supplier to India | Not required to use IRP. Indian buyer handles GST under reverse charge. |
258| Key fields for exports | Supply type = "EXPWP" (export with payment of IGST) or "EXPWOP" (export without payment — under LUT). Shipping bill details required. |
259 
260### Mexico — CFDI (Comprobante Fiscal Digital por Internet) [T1]
261 
262| Element | Rule |
263|---------|------|
264| Mandate | All invoices by Mexican-established entities must be CFDI 4.0 format, issued through a PAC (Authorized Certification Provider) with real-time SAT clearance |
265| Cross-border sales | Mexican entity invoicing a foreign client not registered with SAT must still generate a CFDI through the clearance process. Use RFC "XEXX010101000" for foreign recipients. |
266| Foreign supplier to Mexico | Not required to issue CFDI. Mexican buyer may need to issue a CFDI for the foreign payment (complemento de pagos). |
267| Penalties | Non-compliance: 5%–10% of invoice amount. Fraudulent CFDI: criminal liability (prison). SAT has expedited powers to suspend digital certificates. |
268| Complements | Specific transaction types require CFDI complements: payroll (nómina), foreign trade (comercio exterior), payments (pagos), tax withholdings (retenciones). |
269 
270### EU ViDA (VAT in the Digital Age) — Phased Rollout [T1]
271 
272| Date | Change |
273|------|--------|
274| July 2028 | Deemed supplier rules for platforms (accommodation, transport). Strengthened reverse charge. |
275| July 2030 | **Mandatory e-invoicing for intra-EU B2B transactions.** Digital reporting requirements. E-invoicing becomes default form. EN16931 standard. |
276| 2035 | Italy's SdI derogation expires. Full ViDA alignment required. |
277 
278---
279 
280## Section 8: Archiving Obligations When Invoicing Cross-Border
281 
282### Whose Retention Rules Apply? [T1]
283 
284**Legislation:** VAT Directive Articles 244–248.
285 
286| Rule | Detail |
287|------|--------|
288| **General principle** | Each member state sets its own retention period and format requirements for invoices related to supplies made in its territory. |
289| **Supplier** | Must retain copies of issued invoices per the rules of the member state where they are established. |
290| **Customer** | Must retain received invoices per the rules of the member state where they are established. |
291| **Cross-border** | Both parties retain under their own country's rules. If these differ, the stricter rule is the safest approach. |
292 
293### Retention Periods by Country [T1]
294 
295| Country | Retention Period | Format |
296|---------|-----------------|--------|
297| Germany | **10 years** (§14b UStG) | Original format (paper or electronic). Electronic invoices must remain in electronic form. |
298| France | **10 years** (Art L102B, Livre des Procédures Fiscales) | Electronic invoices in original electronic format |
299| Italy | **10 years** (Art 2220, Codice Civile) | Must be stored via approved electronic conservation ("conservazione sostitutiva") |
300| Spain | **4 years** (Art 29.2, Ley General Tributaria) + additional years if open audit | Original format |
301| Netherlands | **7 years** (Art 52 AWR) | Original format |
302| UK | **6 years** (VAT Regulations 1995) | Original format |
303| Belgium | **7 years** (Art 60 Code TVA) | Original format |
304| US | **Varies by state** — typically 3–7 years for sales tax; 7 years recommended | Any legible format |
305 
306### Key Principles for Cross-Border Archiving [T1]
307 
308| Principle | Guidance |
309|-----------|---------|
310| **Authenticity of origin** | You must be able to prove who issued the invoice (digital signature, EDI, internal controls) |
311| **Integrity of content** | The invoice content must not have been altered after issue |
312| **Legibility** | The invoice must be readable (human or machine) throughout the retention period |
313| **Storage location** | EU: May store outside the member state, but must provide online access to the tax authority on request (Art 247) |
314| **Language** | Some countries (France, Germany, Italy) may require invoices to be in the local language or translatable on request during audit |
315 
316---
317 
318## PROHIBITIONS
319 
3201. **NEVER** issue an intra-EU B2B reverse charge invoice without the mandatory notation. The invoice is legally deficient without it.
3212. **NEVER** assume the supplier's country rules always apply. Check Art 219a — the basic rule is place-of-supply country.
3223. **NEVER** invoice in a foreign currency without documenting the exchange rate used for VAT conversion.
3234. **NEVER** issue a credit note without referencing the original invoice number and date.
3245. **NEVER** assume foreign suppliers to Italy don't need to worry about SDI — if established in Italy, SDI is mandatory.
3256. **NEVER** treat Mexican CFDI requirements as optional for cross-border sales by Mexican entities.
3267. **NEVER** destroy electronic invoices and store only paper copies. Many jurisdictions require retention in original electronic format.
3278. **NEVER** assume one retention period fits all. Apply the rules of your own country AND consider the rules of the transaction country.
328 
329---
330 
331## Test Suite
332 
333### Test 1 — Intra-EU reverse charge invoice, DE to FR
334**Input:** German consultant invoices French company (valid FR VAT) EUR 5,000 for advisory services.
335**Expected:** Invoice follows German rules (Art 219a exception (a)). No VAT. Notation: "Steuerschuldnerschaft des Leistungsempfängers" or "Reverse charge — Art 196 Directive 2006/112/EC." Both VAT numbers on invoice.
336 
337### Test 2 — Italian company invoicing US client
338**Input:** Italian software company invoices US client EUR 20,000 for development services.
339**Expected:** Supply outside EU (Art 219a exception (b)). Italian invoicing rules apply. Must submit XML to SDI (post-July 2022). No VAT (out of scope). Retain for 10 years in electronic conservation.
340 
341### Test 3 — Multi-currency, Maltese company invoicing in USD
342**Input:** Maltese company invoices a Japanese client USD 10,000 for consulting. Place of supply = Japan.
343**Expected:** Maltese invoicing rules (exception (b)). Invoice in USD is fine. If VAT were applicable, convert to EUR at ECB rate on date of supply. Retain for Maltese period.
344 
345### Test 4 — Credit note for OSS sale
346**Input:** German e-commerce seller issued an OSS invoice to an Italian consumer in Q1. In Q2, the consumer returns the goods.
347**Expected:** Issue credit note referencing original invoice. Report the correction on the Q2 OSS return under Italy, not by amending Q1.
348 
349### Test 5 — Mexican company invoicing foreign client
350**Input:** Mexican SaaS company invoices a Colombian client $5,000/month for software.
351**Expected:** Must issue CFDI 4.0 via PAC with real-time clearance. Use RFC "XEXX010101000" for foreign recipient. Complemento de comercio exterior may be required.
352 
353---
354 
355## Disclaimer
356 
357This skill and its outputs are provided for informational and computational purposes only and do not constitute tax, legal, or financial advice. Open Accountants and its contributors accept no liability for any errors, omissions, or outcomes arising from the use of this skill. Invoicing requirements are evolving rapidly due to e-invoicing mandates worldwide. Always verify current rules with official sources and a qualified advisor.
358 
359*Data reflects 2025–2026 rules. OpenAccountants — open-source accounting skills for AI — info@openaccountants.com*
360 

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Cross-border invoicing rules — which country's requirements apply, what goes on the invoice, and how to handle e-invoicing mandates. Use when the user asks about: cross-border invoice, invoicing foreign client, reverse charge invoice, multi-currency invoice, self-billing cross-border, credit note cross-border, e-invoicing cross-border, which invoicing rules apply, Article 219a, supplier country invoicing, Italy SDI foreign, India IRN cross-border, Mexico CFDI foreign, invoice retention cross-border, archiving invoices, ECB exchange rate, VAT currency conversion, recipient-created invoice, or any question about the correct format, content, or process for invoices crossing borders.

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