Will E-Invoicing Make Self-Billing Obsolete?
Will E-Invoicing Make Self-Billing Obsolete?
The automotive industry has long relied on self-billing, where manufacturers issue invoices to themselves on behalf of their suppliers, to streamline operations and maintain efficient cash flows. But with the global shift towards mandatory e-invoicing, businesses are questioning whether self-billing can continue to coexist with these new digital mandates.
From a VAT perspective, in a self-billing arrangement:
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The customer (e.g., an automotive manufacturer) creates the invoice for the supplier.
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The supplier (e.g., a parts producer) must agree to this arrangement in writing.
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The invoice must meet all the VAT invoicing requirements of the jurisdiction, even though it was not issued by the supplier.
- Both parties remain responsible for ensuring that the VAT is applied correctly and reported to the tax authorities.
Why It Matters for VAT Compliance
While self-billing improves operational efficiency, it faces multiple VAT challenges:
- Responsibility is shared and both customer and supplier are on the hook if VAT is incorrect.
- Some countries allow self-billing only under strict conditions, while others prohibit it altogether.
- If the invoice does not meet the local VAT rules, tax authorities may disallow input VAT deductions, leading to financial exposure.
- In multinational cross border supply chains, ensuring self-billed invoices comply with different VAT regimes can be very difficult.
- Ensuring self-billed invoices meet government e-invoicing formats can be complex, particularly in legacy systems like SAP.
- Real-time e-invoicing leaves no room for error, and discrepancies can lead to rejected invoices or penalties.
- Non-compliance can result in fines, legal disputes, and strained supplier relationships.
The Rise of E-Invoicing
E-invoicing mandates are being implemented worldwide to enhance VAT compliance and automate audit processes. Countries like Germany, France, Poland, and Italy will require invoices to be issued in structured digital formats and submitted through government-approved platforms. These regulations often expect suppliers to issue invoices themselves, introducing a challenge for manufacturers used to self-billing.
A Practical Example: Italy
Italy provides a clear example of the practical barriers to self billing with e-invoicing. In Italy, e-invoicing is applicable only to Italian-established suppliers. In order to issue a self-billed invoice, the customer must be registered with the Italian SDI (Sistema di Interscambio), however, only entities established in Italy can register, creating a challenge for foreign manufacturers.
While the customer can still technically issue a self-billed invoice without using the SDI, this doesn’t remove their supplier’s obligation to issue an e-invoice via the SDI and so could potentially lead to double invoicing or risk of input VAT deduction rejection.
This shows that self-billing is not universally compatible with e-invoicing rules, and other countries may adopt similar structures in the future, particularly in the EU. The benefits of self-billing could be eroded by e-invoicing rules.
Navigating the Future: Can Self-Billing and E-Invoicing Coexist?
Despite these challenges, self-billing is unlikely to disappear entirely. Likely trends include;
- Hybrid approaches Manufacturers continue to self-bill, but invoices are converted into e-invoices before submission.
- Government-approved self-billing Allowed under certain local conditions with proper registration or agreements.
- Stronger VAT automation Ensures self-billing reconciles seamlessly with e-invoicing mandates.