Credit notes changes: date of taxable supply and inclusion in tax return
The amendment to the credit notes handling rules is one of the most practical and often neglected changes to the tax package effective from 1 April 2019.
It is no longer enough to issue a credit note to the supplier within the 15-day period from the date of the facts decisive for issuing the corrective tax document (the “decisive day”). The supplier must now make sufficient efforts to get the document into the hands of the recipient. This will usually be done using the same delivery method as regular invoices.
The record date is a new mandatory part of the corrective tax document. The tax correction is considered a separate taxable supply; the record date is the date of the taxable supply. This and other obligations have been effective since 1 April 2019, without any exceptions.
These changes then have a significant impact on the correctness of the reporting in the tax return or control statement. If the tax is increased by the correction, the supplier must specify the correction for the tax period to which the reference date falls. The supplier no longer has the option to “postpone” the correction. On the other hand, in case of a tax reduction, the law implements a very positive change. The supplier no longer must wait for the recipient to confirm receipt of the document; it is enough for the supplier to make adequate efforts to deliver the credit note.
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