Electronic invoice to customers without a VAT number: it must be done, here's how

Question: when a lawyer receives a payment from a client without a VAT number, does he have to issue an electronic invoice? The answer is yes, always. The same goes for architects, surveyors, engineers and so on. In fact, according to the new rules, companies and workers subject to the digital invoicing obligation - extended from 2019 also to relations between private individuals - cannot make exceptions for natural persons who only have a tax code.

However, there are some differences and they concern the compilation of the invoice.

WHAT CHANGES IN THE ELECTRONIC INVOICE

 If the recipient is a private individual without a VAT number, the person issuing the electronic invoice must take two precautions:

• write “0000000” (seven times zero) in the “Recipient Code” section;
• fill in the customer's "tax code" field.

If one of these two requirements is not respected, the digital platform of the tax authorities (il Exchange System, SDI) rejects the invoice, which is therefore not issued.

PAPER OR PDF INVOICE

But it's not over. The person issuing the invoice is also required to deliver a hard copy of the document to the customer or to send him one via email in PDF format. However, the obligation is not mandatory, in the sense that the customer can waive this right (preferably in writing).

THE E-BILL ON THE REVENUE SITE

Why would he ever do that? Simple: even those who do not have a VAT number receive (directly from the tax authorities) a copy of each electronic invoice addressed to them. To consult it, just go to your reserved area on the portal "Invoices and Fees” of the Revenue Agency. The section to be identified is called "Relevant data consultation for VAT purposes" and is next to the one dedicated to the pre-compiled tax return.

In theory, the person issuing the invoice should make this possibility clear to the customer (also to convince him to give up the paper or PDF invoice).

THE ALTERNATIVE OF THE PEC

Customers can also choose to receive electronic invoices via certified mail. It is sufficient to communicate the Pec address to the supplier, who however will not have to limit himself to sending an e-mail to the customer, but will still have to go through the Exchange System.