НАЗАД

Question: The measurement unit and the number of goods are already indicated in Columns 2, 2a and 3 of the VAT invoice. Why do you need to fill in Columns 12, 12a and 13? 

Ulyana Toria: These data differ in that Columns 12, 12a and 13 provide indicators in measurement units used for the traceability purpose, which are indicated in the List of goods subject to traceability in the Russian Federation (as of the date of this answer, the List has not yet been approved and exists only as a draft. It is expected to be approved at the end of June 2021), and Columns 2, 2a and 3 indicate the measurement units and the number of goods that are used in the organization and that may differ from the measurement units used for the traceability purpose.

 Question: The company does not apply electronic document management. How should it arrange the exchange of documents and reports related to goods subject to traceability?

Ulyana Toria: To control traceable goods, the company is required to switch to electronic document management, include new details in VAT invoices and other documents, and submit additional notices and reports via telecommunication channels.  Therefore, to get prepared to handle traceable goods, you need to, among other things:

• obtain an electronic signature;
• switch to electronic document management and set up accounting software.

Clause 1.1, Article 169 of the Russian Tax Code: When goods subject to traceability are sold, VAT invoices, including corrective VAT invoices, shall be issued in electronic form, except when:

1) goods subject to traceability are sold to individuals for their personal, family, household and other needs not related to entrepreneurial activity, or to self-employment tax payers;

2) goods subject to traceability are sold and exported from the Russian Federation in accordance with the customs procedure for export (re-export);

3) goods subject to traceability are sold and exported from the Russian Federation to another state that is a member of the Eurasian Economic Union.

(Clause 1.1 was put into effect by Federal Law No. 371-FZ dated November 09, 2020)

     Clause 1.2 Article 169 of the Russian Tax Code: When purchasing goods subject to traceability, organizations and/or individual entrepreneurs shall ensure receipt of VAT invoices, including corrective VAT invoices, in electronic form via telecommunication channels through an electronic document management operator which shall be a Russian organization and meet the requirements approved by the federal executive body authorized to control and supervise taxes and fees.

(Clause 1.2 was put into effect by Federal Law No. 371 dated November 09, 2020) 

Moreover, when dealing with goods subject to traceability, non-payers of VAT (applying the simplified tax system or applying the general tax system, but granted VAT exemption) shall issue universal transfer documents and universal corrective documents in electronic form according to the formats approved the Federal Tax Service with traceability details reflected therein.  

The electronic document management procedure was approved by Order of the Ministry of Finance of Russia on the electronic document flow of invoices, dated February 05, 2021, No. 14n (registered with the Ministry of Justice of Russia on March 12, 2021, No. 62737).

Beginning from January 01, 2023, electronic document management operators shall submit VAT invoices (universal transfer documents) they have received to the Federal Tax Service within one business day following the day of their receipt.

In general, the Russian tax system is evolving towards the transition of all taxpayers to electronic document management. It can be assumed that all taxpayers will have to switch to electronic document management in the near future.

Question: VAT invoices for traceable goods are submitted via electronic document management only. Has the printed form of VAT invoices changed?

Ulyana Toria:  Yes, it has changed. If the goods are not subject to traceability, you needn’t print additional Columns 12, 12a and 13, but you have to print additional details set for all taxpayers.