Invoicing deadline

What it means

The invoicing deadline is the time within which a VAT payer must issue an invoice after supplying goods or services or receiving an advance payment. It is set by the VAT Act and runs from the event that gives rise to the tax, not from whenever the supplier remembers to invoice.

For domestic supplies the deadline runs from the supply or from receipt of an advance. For an intra-EU supply of goods and for services on which the customer in another country pays the tax, the law sets a deadline tied to the end of the month in which the supply took place.

The invoice date does not determine when the tax arose. The tax becomes due on the tax point, the date of supply or of payment, regardless of when the invoice was issued. A late invoice therefore does not move the tax; it only breaches the obligation.

How it works in practice

In day-to-day work we recommend issuing invoices straight after supply or at the latest at the monthly close. For recurring services such as rent or a retainer, partial performance can be agreed and invoiced once a month.

An invoice, or more precisely a tax document for the payment, is issued for an advance received, and the advance is settled on final delivery. If this is not done in time, the VAT on the advance must still be declared in the period the payment was received.

Besides meeting the deadline, the invoice must carry all the required particulars. Audits check both: whether invoices were issued on time and whether they contain everything the customer needs to claim a deduction.

What to watch out for

The most common mistake is invoicing at quarter end for supplies made at its start and declaring the tax by invoice date. The tax is then declared in the wrong period, assessed again with interest, and late invoices can also bring a penalty.

With EU customers, a late invoice also affects the EC sales list, which must match the period of supply. A mismatch between the EC sales list and the partner’s return in another country often triggers questions from the tax office.