The mandatory use of e-invoicing in the B2B context in Spain is imminent, following the enactment of the Crea y Crece Law. However, in regions such as Latin America, it has been a long-standing reality.
A prominent expert on the implementation of e-invoicing in the global context is Jesús Ricart, a tax consultant with extensive experience in electronic invoicing at the international level. We conducted an interview with him to obtain information that would facilitate an understanding of the global context of e-invoicing.
Q: It is evident that your professional trajectory has been inextricably linked to the domain of international e-invoicing, and that you have assumed consultancy roles in a multitude of geographical regions. In which countries or regions is e-invoicing currently being adopted most rapidly, and are there any significant differences between these countries or regions that lead you to hold this opinion?
J: From my perspective, the answer to this question is straightforward: the prevailing legal framework for electronic invoicing (with a significant emphasis on tax regulation and as a tool to combat tax fraud) provides a clear indication of the current state of affairs. This phenomenon was originated in Latin America and was initially adopted by countries such as Mexico, Brazil and Chile, where it set a precedent that subsequently spread eastwards towards Europe, the Middle East and, most recently, the countries of the Asia-Pacific region. From my own perspective, having had the opportunity to work in several different regions and to gain direct experience of this phenomenon in Europe and America, I am currently observing with interest the gradual implementation of e-invoicing obligations in countries in the Middle East and Asia-Pacific.
"It is imperative that we extend our focus beyond tax fraud if we are to achieve success with e-invoicing"
Q: In light of the forthcoming implementation of the Crea y Crece Law in Spain, it is becoming increasingly clear that e-invoicing will become a mandatory requirement in our country. For a considerable period of time, you occupied the role of Director of Indirect Taxes in Latin America, a region that was at the vanguard of the introduction of electronic invoicing. What insights can be gleaned from these experiences to ensure the success of the legislation in Spain?
J: As previously stated, Ibero-American countries have been at the forefront of implementing rigorous tax regimes for e-invoicing, with the objective of combating tax fraud. These experiences offer a valuable insight: organisations initially viewed e-invoicing as a mere tax compliance issue. This was the approach taken by tax authorities in the region, which failed to stimulate debate on the potential benefits of e-invoicing in terms of efficiency and process automation.
It is therefore evident that an approach in which a Government body other than the Tax Administration is responsible for promoting the introduction of electronic invoicing, in collaboration with various private sector operators and with objectives extending beyond the fight against tax fraud, is the most appropriate approach.
This approach has been adopted in Spain with the introduction of the “Crea y Crece Law”, and in the United Arab Emirates, where the Ministry of Finance is spearheading the implementation of an e-invoicing regime based on the PEPPOL standard, which is scheduled to come into effect in July 2026. Such implementation is not solely aimed at combating tax fraud; rather, it is embedded on a wider initiative to promote the digitalisation of business processes in companies operating in the United Arab Emirates.
Q: What challenges do you think Chief Compliance Officers, Group Head of Tax & Treasury, Global Head of Tax, Senior Tax Manager, Global Head of Tax, Treasury & Customs, Director Taxation, Head of Indirect Tax and Tax Officers of companies and individuals in our country will face in the short term when dealing with e-invoicing related taxes? And in the long term?
J: In the short term, and according to conversations with other in-house tax managers working for different companies, I have noticed that the priorities are around managing the existing internal processes in their respective organisations, aimed at implementing e-invoicing in different countries and beyond the geographical scope of the European Union.
In the context of these projects, there is a broad debate within the organisations about who should lead the project, the responsibility and also accountability of the different departments involved in the project and what the priorities of the project should be and, to be honest, there are different approaches to the implementation of e-invoicing in different countries as in terms of execution, The in-house tax manager's priority is to ensure compliance with tax regulations and to be an important project stakeholder, accountable for the outcome of the project, but not the one ultimately responsible for the project, since any problems that may arise in the implementation of electronic invoicing become a business risk whose repercussions go beyond the implications derived solely from the sanctions regime within the tax framework.
"The key to ensuring the long-term future of e-invoicing within a company is to engage the services of an external supplier"
In the long term and given the dynamic nature of the requirements set out in the different national e-invoicing regimes, the challenge is implementing a model that is sufficiently flexible to be able to cope with the continuous and demanding changes in requirements in different countries at the same time. To this end, I believe that the selection of an external vendor capable of supporting the company in this continuous process of adaptation to the changing requirements that the implementation of electronic invoicing processes entails is critical.
Q: If we focus on a much more operational and/or logistical level, what characteristics do you consider essential for implementing an e-invoicing project on an international scale?
In my point of view, implementing an e-invoicing project requires the following:
As failure to comply with e-invoicing requirements can cause disruption to a company's supply chains and is a business risk. Consequently, the implementation project must have a governance structure that actively involves the company's top management and clearly defines the responsibility (and accountability) of the various departments involved.
The project must identify the opportunities offered by the implementation of electronic invoicing in terms of efficiency and business process improvement, which requires appropriate management of internal stakeholders with a multidisciplinary approach. In my view, the project must be led by the technology department, with strong intervention from the internal tax team as subject matter expert to verify compliance with tax requirements and from the operational business areas to prevent circumstances that could lead to disruptions in business processes.
Finally, as I mentioned earlier, the need for the project to cover different jurisdictions is a challenge that goes beyond the internal capabilities of companies and makes it necessary to select a vendor specialised in e-invoicing services who can support the e-invoicing implementation work in the countries where the company operates.
Q: At the European level, all countries are focusing on the VAT in the Digital Age initiative (ViDA project). It is supposed to change the paradigm of e-invoicing at European level, is it as significant as it is thought to be and do you think it will achieve 100% acceptance?
J: The e-invoicing pillar of the VAT in the Digital Age (VIDA) initiative is a much-needed step towards preventing the European Union from becoming a 'digital tower of Babel' and towards common parameters for all Member States in terms of tax rules for e-invoicing and real-time reporting. However, some experts have pointed out that the proposal may come too late and may lack ambition.
As far as the approval of the proposal is concerned, the need for unanimity in the ECOFIN Council and the lack of unanimity on another pillar of the proposal (the relative VAT regime for digital platforms) is currently delaying its adoption, which I understand could be an incentive for EU Member States to consider continuing their respective national projects to implement a differentiated regime for e-invoicing, which could aggravate the problem of the challenge created by the disparity of requirements.
“The use of artificial intelligence will increase the automation of e-invoicing processes”
Q: According to various experts, artificial intelligence, which is already very present in our daily lives, will become an essential tool for the future of e-invoicing. Do you think it will change the way e-invoicing is done? If so, why? Do you think the tax authorities will be ready when the time comes?
J: Over the past 12 months, there has been an acceleration in the use of artificial intelligence in various tax management processes, such as the tax compliance automation data processing related to transfer pricing. My expectation is that the use of AI will increase the automation of electronic invoicing processes, as it will be a key tool to improve the quality of data used in this type of process, which is an essential element.
Several tax authorities around the world are ready and already using artificial intelligence in tax management processes as a tool to prevent tax fraud. This is possible to the extent that the quantity and quality of taxpayer data in their possession is increasing, which is a prerequisite for the use of artificial intelligence on their part. I understand that the debate should focus on the adoption of measures that ensure the protection of taxpayers' rights and avoid any bias in the processing of taxpayers' data by artificial intelligence tools used by any tax administration.
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Jesús Ricart is a Tax Consultant who has worked in different firms and multinational companies, gaining extensive experience both in tax practices as well in-house in areas such as indirect, corporate or international tax, tax technology and tax department transformation. Jesús has successfully managed VAT implementation projects, ERP tax configuration, e-invoicing, tax restructuring or tax dispute resolution in different jurisdictions in Europe, Latin America and the Middle East. He is also involved in various initiatives aimed at promoting the debate related to the implementation of technology in the field of taxation. |
