E-invoicing: also for Dutch entrepreneurs sooner than expected
E-invoicing: also for Dutch entrepreneurs sooner than expected
The ViDA-proposals, adopted by EU Member States on 11 March 2025, introduce new rules on e-invoicing. A few of these rules have already been in effect since April 14 2025. These rules make it easier for Member States to make e-invoicing mandatory and require recipients to accept these e-invoices. This rule, however, only applies to entrepreneurs establishes in a certain Member State. Although the Netherlands has no formal plans to introduce e-invoicing and digital reporting requirements before July 1 2030, it is expected that Dutch entrepreneurs will have to deal with these obligations earlier due to developments in practice.
Member States are not required to implement the requirement for all domestic transactions and all entrepreneurs established in their Member State. They can also limit it to specific transactions or groups of taxpayers. A phased introduction, where e-invoicing becomes mandatory for large businesses first and later for smaller businesses, for example, is possible. The e-invoicing obligation can be introduced for both B2B and B2C transactions.
There are already Member States that have made e-invoicing mandatory by obtaining a derogation in the past. It is possible that other Member States will now do the same, as it has been made easier.
Dutch companies doing business with entrepreneurs in other EU Member States where e-invoicing is mandatory may have to deal with a supplier or customer asking for e-invoices. Additionally, developments such as digital reporting requirements in other Member States may cause Dutch entrepreneurs to voluntarily switch to e-invoicing in order to report more efficiently. These digital reporting obligations can also be imposed by EU Member States on non-established entrepreneurs who make or purchase taxable supplies in that EU Member State. The information to be reported digitally can easily be extracted automatically from such an e-invoice.
E-invoicing also offers several benefits, including faster access to data, improved cash flow, more efficient inventory management and reduced use of paper. These benefits can encourage businesses to voluntarily implement e-invoicing even before it becomes mandatory.
We also expect that EU Member States that have introduced an e-invoicing obligation may argue that a Dutch entrepreneur has a fixed establishment when having a presence on the territory of their EU Member State (e.g. in the form of a warehouse). We expect a broad interpretation of the fixed establishment concept in this regard. Of course, we can help you identify whether you have such a fixed establishment in the EU Member State that has introduced an e-invoicing obligation and whether such an obligation can be imposed on you.
In other words, you may already be dealing with e-invoicing in the short term. It is therefore important that you prepare in good time for the technical and administrative adjustments that e-invoicing entails. BDO can of course help you with this.
What is e-invoicing?
E-invoices are digital invoices. However, they are not a digitally created paper invoice, such as a pdf. An electronic invoice (e-invoice) is an invoice that has been issued, transmitted and received in a structured data format, which allows for automatic and electronic processing. From July 1 2030, e-invoicing for VAT will be mandatory for cross-border transactions within the EU. We informed you about this earlier.New rules for introduction of e-invoicing
Member States wishing to introduce e-invoicing until April 14 2025 needed to obtain a derogation for this This will no longer be necessary from that date. Member States can now oblige entrepreneurs to issue e-invoices and require recipients to accept them. This is only allowed for domestic transactions and if both supplier and the recipient are established on the territory of the EU Member State introducing the obligation. The new rules do not apply to intra-community transactions and in international services where VAT is reverse charged to the customer.Member States are not required to implement the requirement for all domestic transactions and all entrepreneurs established in their Member State. They can also limit it to specific transactions or groups of taxpayers. A phased introduction, where e-invoicing becomes mandatory for large businesses first and later for smaller businesses, for example, is possible. The e-invoicing obligation can be introduced for both B2B and B2C transactions.
There are already Member States that have made e-invoicing mandatory by obtaining a derogation in the past. It is possible that other Member States will now do the same, as it has been made easier.
Consequences for Dutch entrepreneurs
At present, the Netherlands is not expected to make e-invoicing mandatory for transactions subject to VAT in the Netherlands in the near future. Nevertheless, Dutch entrepreneurs may already be faced with these obligations.Dutch companies doing business with entrepreneurs in other EU Member States where e-invoicing is mandatory may have to deal with a supplier or customer asking for e-invoices. Additionally, developments such as digital reporting requirements in other Member States may cause Dutch entrepreneurs to voluntarily switch to e-invoicing in order to report more efficiently. These digital reporting obligations can also be imposed by EU Member States on non-established entrepreneurs who make or purchase taxable supplies in that EU Member State. The information to be reported digitally can easily be extracted automatically from such an e-invoice.
E-invoicing also offers several benefits, including faster access to data, improved cash flow, more efficient inventory management and reduced use of paper. These benefits can encourage businesses to voluntarily implement e-invoicing even before it becomes mandatory.
We also expect that EU Member States that have introduced an e-invoicing obligation may argue that a Dutch entrepreneur has a fixed establishment when having a presence on the territory of their EU Member State (e.g. in the form of a warehouse). We expect a broad interpretation of the fixed establishment concept in this regard. Of course, we can help you identify whether you have such a fixed establishment in the EU Member State that has introduced an e-invoicing obligation and whether such an obligation can be imposed on you.
In other words, you may already be dealing with e-invoicing in the short term. It is therefore important that you prepare in good time for the technical and administrative adjustments that e-invoicing entails. BDO can of course help you with this.
