New invoice codes for use the plafond

With the provision No.99922/2020, the Revenue Agency has introduced new encodings for the correct transmission of e-invoices by Sdi.
These changes affect, among others, who wish to obtain the status of regular exporters in order to accrue the plafond for the purchase of goods and services without VAT application.

The new encodings concern the type and nature of the document and will be required from 1st October 2020. However, they can be used, optionally, from 4 May 2020.

Non-taxable transactions that contribute to the determination of the plafond will be identified with the codes N3.1-N3.2-N3.3-N3.4. The new encoding reproduces the partition of the VE30 row fields of the VAT return, in view of the pre-compiled’s draft planned for operations 2021.

Code N3.1 will cover the transfer to export ex art. 8 paragraph 1 lett. (b) and b-bis) of DPR 633/72 and will include the disposals of “triangular” exports and the extractions from the VAT warehouse with transport or shipping outside the EU(article 50-bis paragraph 4 lett. g) of DL 331/93).

Code N3.2 will identify intra-community disposals (Article 41 commi 1 and 2 of DL 331/93), including ‘triangular’ and extractions from VAT deposit with transport to another EU state (article 50-bis paragraph 4 lett. f) of DL 331/93).

Code N3.3 will be attributable only to disposals to operators residing in the Republic of San Marino (art. 71 of DPR 633/72).

All other non-taxable transactions that contribute to the formation of the plafond will be identified by code N3.4. These include international services (article 9 paragraph 1 of DPR 633/72), operations with Vatican City (article 71 of DPR 633/72) and international inspection bodies (article 72 of DPR 633/72).

New technical specifications will also be introduced for the providers. These interested parties will issue the document under a non-taxable basis using the

N3.5 code and at the same time will have to enter the details of the protocol of receiving the letter of intent as a result of art. 12-septies of DL No.34/19.

A special feature of the new provisions will relate to the margin of non-taxable transactions relating to used goods (Article 37 paragraph 1 of DL 41/95). The non-taxable margin identifiable by code N3.1 or N3.2 has to be isolated from the share part of the fees, which will instead be associated with the new code N3.6 (used for all non-taxable transactions that do not contribute to the formation of the plafond).

Finally, it’s important to clarify that it is possible to regularize any splaphoning (purchases beyond the limit of the available plafond ex art.7 paragraph 4 of DLgs 471/97) by issuing an electronic invoice sent to the Sdi, with the specific document type “TD21”.