Discovering e-Invoicing in Africa: Regulations and Developments
In this webinar, we take a deep dive into the evolving landscape of e-Invoicing in Africa, focusing on the regulatory frameworks and recent developments that are shaping the way businesses operate.
Discovering e-Invoicing in Africa: Regulations and Developments
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In Africa, governments and businesses are adopting e-Invoicing solutions to streamline processes and drive economic growth.
Stay up-to-date with the latest developments and initiatives driving e-Invoicing adoption in the region to understand the implications for your business.
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Compliance
Any updates on implementation dates for South Africa?
SARS published a discussion paper on VAT Modernisation in 2023, inviting vendors to submit contributions and comments and to engage on intended measures. In the discussion paper, SARS indicated that the digital transformation for VAT is likely to start with the request of more data to support the VAT return submissions. They have not indicated when this would be implemented however, they mention that their overall VAT modernisation journey is approximately five years.
Is it correct that e-Invoicing and e-Reporting are applicable only for companies with a permanent establishment in that country but not for companies exporting to the African country?
E-invoicing requirements for imports can vary significantly by country and the specific regulations and requirements relevant to that country would need to be considered.
Here is an overview of how some African countries are handling e-Invoicing for imports:
- Tanzania- The TRA mandates e-Invoicing for all registered businesses including importers. Import transactions must be recorded through the Electronic Fiscal Device Management System.
- Kenya-The Kenyan Revenue Authority requires importers to use the iTax system to generate electronic tax invoices.
Other African countries may have similar requirements with respect to importers and for a more accurate answer, it's best to consider the specific country and their legislative requirements.
Will these legislations apply to non-resident entities registered for VAT in those countries?
E-invoicing regulations and their applicability vary by country. As non-resident entities are generally required to register for VAT should they meet the threshold, the legislative requirements pertaining to e-Invoicing will be applicable to them. In certain countries we've seen that e-Invoicing extends beyond registered VAT vendors, for example: in Kenya, the Revenue Authorities have extended the e-Invoicing requirements to non-VAT registered vendors with the intention to gain insights into all the transactions occurring in the Kenyan market.
It is likely that some countries may eventually expand the scope of e-Invoicing to include non-registered VAT vendors as the system matures and the infrastructure becomes more robust.
For Zambia and Kenya, is it real time reporting of transactions, like SII reporting in Spain, or is it true e-Invoicing? And, is there also the obligation to report received invoices, not only issued?
The model in both instances (Kenya & Zambia) is a clearance model. This constitutes e-Invoicing and requires businesses to declare their sales invoices to the tax authority before sending them to the final buyer. Only sales invoices on the AR flow are required to be declared since your suppliers will have already declared their invoices to the tax authority before sharing them with your business.
When is it expectable that Botswana implements the electronic invoice?
There has been no official press release on the implementation of e-Invoicing in Botswana. The expected date for any further information to be released is in July 2024.
Can you explain what is the TIN number?
A Taxpayer Identification Number (TIN) is a means of uniquely identifying taxpayers or potential taxpayers (i.e. individuals and corporate bodies) for tax purposes. E.g. for Ghana, the GRA TIN is a distinctive 11-digit alpha-numeric identifier assigned to individuals and entities in Ghana.
Are you able to share with us the deadlines of the upcoming e-Invoicing mandates in the African countries?
- South Africa- Timeline has not yet been published.
- Botswana - Timeline has not yet been published.
- Zambia - 1 July 2024
- Malawi - New timeline for move to e-Invoicing from fiscal devices has not yet been published
- Cameroon - Timeline has not yet been published.
- Mauritania - Timeline has not yet been published.
ZRA (Zambia) advised that they are still conducting UAT's before a list of approved vendors (for smart invoicing) can be published. Is Deloitte aware of possible extension to implement (considering that the effective date for Smart invoicing is 1st of July 2024)?
There has been no announcement from the Zambian Revenue Authorities regarding extensions. Full implementation will commence from 1 July 2024.
For the most up to date information, keep an eye on official announcements from the Zambian Revenue Authority website.
Is the e-Invoicing required by the revenue control authority / authorities in Africa (XML / JSON) approved by GS1? Is the template available?
Each country dictates its e-Invoicing mandate, including the legal format of the invoice.
On the African map slide, you categorized Kenya as "electronic invoicing", instead of "fiscal device". Our understanding is it requires a physical device called a Control Unit to communicate with the Kenya Revenue Authority. Can you clarify?
In Kenya there are two types of control unit
- Virtual sales control unit
- Online sales control unit
Both solutions are digital platforms that enable the transmission of company data directly to the Kenyan Revenue Authority (KRA) by way of application programming interfaces (API) provided by either the KRA or a certified vendor.
As such, no physical device is required.
Can we know which countries within Africa have already implemented e-Invoicing/e-reporting requirements?
The countries that have already implemented e-Invoicing or e-reporting are as follows:
- Kenya
- Angola
- Uganda
- Tanzania
- Ethiopia
- Ghana
- Nigeria
- Egypt
- Mauritius
- Malawi
How are invoices signed in the Ghana context? Do companies need to be certified by a certification authority?
No, invoices do not need to be electronically signed in Ghana before they are submitted to the tax authority. As such there is no need to be certified by a certification authority before your business can begin e-Invoicing. When e-invoices are submitted to the GRA, it is their responsibility to apply what we call SDC information (Sales Data Controller) such as a timestamp, invoice ID, hash, and QR code. This SDC information will demonstrate that the invoice has been validated and authenticated by the GRA, as such eliminating the need for the supplier to also digitally sign the invoice.
Have you seen authorities enforcing e-Invoicing more from a VAT compliance perspective or do you also see non-deductibility of expenses not compliant with e-Invoicing from a CIT perspective?
In Kenya, it is mandatory to comply with e-Invoicing for all transactions.
Where compliant e-invoices are not received from vendors through the KRA's platform, the entity will not be allowed to claim the related expense as a deduction from a corporate income tax perspective.
For an invoice to be compliant, it needs to be stamped by with a QR code that can only be generated through e-Invoicing platforms.
EDICOM Platform
In Zambia, defining stock is very challenging for complex manufacturing companies (stock can be finished good, semi fished good to use in the next manufacturing phase, raw materials etc).
Correct, the e-Invoicing mandates often push companies to streamline and automatize business processes in a larger scale. EDICOM solutions can help in this process with integrations and data enhancement.
Does EDICOM's solution run on / prem or in the CLOUD?
All EDICOM solutions are cloud based. EDICOM hosts its own data centers.
Does the e-Invoicing platform maintain the same invoice reference number as would have been generated from normal company ERP system or does it generate its own? If the latter, how do you maintain consistency from an audit trail perspective?
Consistency is maintained. The ERP reference number is included, and there is also a reference number created by EDICOM platform. Furthermore, many countries add a unique identifier, which is a reference number provided by the tax authority to identity each invoice. All these reference numbers coexist in the EDICOM platform.
Given that many African countries face significant challenges related to digital infrastructure and connectivity, how can business (clients), particularly multinational companies effectively implement e-Invoicing solutions in regions with limited technological resources?
EDICOM offers cloud-based solution, which overcomes many of the technological limitations of the countries. A basic Internet connection is required to access the web interface.
Is this global solution able to manage various VAT compliance models, i.e. 4 corner model + other models?
Yes, EDICOM offers a single global platform with a modular approach, and it can be adapted to any e-Invoicing model (clearance, interoperability, CTC, centralized exchange, etc.) and country specific requirements.
Does the EDICOM Cloud Based Global Solution offer enrichment functionality? For example: Purchase Order isn't putted in the expected field, but somewhere in a text field, is your solution be able to get that Purchase order and add it to the field where it is expected.
Yes, EDICOM solution offers different functionalities for data enhancement and business requirements, such as equivalence list, data merging and many more.
Do you have a casing point in which you have assisted the taxpayers on the inventory and AP side, AR is generally straight forward. Thanks
Yes, EDICOM has successfully implemented thousands of AP projects. With our background in data exchange and EDI, our expertise and our versatile platform, we can provide different solutions for AP flow, including vendor portals, integration with OCR software, AP invoice download from public portals, EDI reception, managed email, etc.
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