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The new requirements for VAT invoicing that came into force on 1 January 2004 have caused confusion among finance and technology professionals.

The EU Invoicing Directive aims to simplify and harmonise rules on invoicing across the region, but recent commentary is unclear on the subject of sending invoices electronically.

One response to the Invoicing Directive was published in a press release from software startup Global Invoice Corporation that read: “All electronic invoices will need to demonstrate ‘authenticity of content’ and ‘origin’. This rules out using email as a method of sending invoices because the content and origin of an invoice sent by email can be intercepted and the contents altered. So, from 1 January, you will no longer be able to send an invoice by email.”

The Business Application Software Developers Association (BASDA) quickly published a note saying: “This is an untrue and misleading statement from an opportunistic organisation which is hoping to sell a service,” said Dennis Keeling, CEO of BASDA. “UK companies (can) continue to send invoices electronically by email, without needing digital signatures.”

So what is the truth? David Watt of HM Customs and Excise told software provider Intuit in a press release on the subject: “Invoicing by email is optional under the provisions of the directive on invoicing. It is business itself that should determine whether to invoice in this way.”

And while the EU Directive does allow for electronic invoicing that is protected by a secure digital signature, a later domestic publication, Notice 700/63 Electronic Invoicing, says that HM Customs & Excise will continue to allow unsigned fax and email invoices and the posting of invoices on a website.

So UK businesses don’t have to send invoices electronically but will they have to receive them as the Financial Times suggested in December 2003? “Companies will be forced to accept e-invoices on 1 January when a directive comes into effect,” it said.

A Customs & Excise briefing note makes clear that it’s not compulsory to take invoices electronically; it is permitted if both the receiver and sender wish to invoice electronically.

“If a business is not e-enabled, it may not be able to receive e-invoices. Whether e-invoicing is appropriate is a commercial matter, and there is nothing in the changes to oblige you to e-invoice or make your customer accept it if they don’t want to.”

Guidance for the implementation of the EU Invoicing directive is available at

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