In this material you will find Questions and Answers More frequent and in accordance with technical and legal specifications issued by the Accountants' Associations, which will be updated at various stages of the Fiscalization project's implementation.
The case of canceling a prepayment invoice is a credit invoice – the system doesn't allow you to issue a credit invoice.
Answer – An advance payment invoice is a regular fiscalized invoice. In the case of an invoice that also includes the advance payment made, the NIVF of the issued advance payment invoice must also be referenced. The issue raised applies only during the transitional phase, since once full fiscalization is implemented, this problem will no longer exist.
In Self-Care, the Purchase and Sales books do not show the clients' names, only the NIPT. The client's or supplier's name must also be recorded because it causes difficulties when completing the VAT book in Excel.
Answer – During the transition period, the declaration of books will be done manually through e-filing. After the September 2021 period, their reporting will be done automatically. Detailed purchase and sale transaction data appears in the menu: Purchase and Sale Book – Monthly Summary – Purchase/Sale Book Item.
Also, in the bill lists in Self-Care, when they are in a foreign currency, only the amounts in the foreign currency are displayed and not in Lek.
Answer – In the Sales and Purchase books, invoices are recorded in Lek, regardless of whether they may have been issued in foreign currency. However, to facilitate handling this issue, it is necessary to submit concrete cases, NIPT, NIVF, and NSLF.
It often happens that invoices, even though they are fiscalized, when you try to print them as PDF you get a message that printing cannot be done because this service is not offered.
Answer – This problem occurred during deploy-t held on August 2-4 and has now been resolved.
The issue of listing only one account on the invoice: When the invoice is created, it is intended that only one bank account be selected. But the client may have another account, and banks will not pay an invoice if the invoice lists a bank account number from a different bank. It needs to be fixed by DPT so that more than one bank account can be declared on the invoice.
Answer – The proposed solution is not possible. The parties' intent regarding the settlement of the invoice must be fulfilled. Even if the taxpayer goes to the bank to make a payment to an account different from the one specified and displayed on the QR code, the bank does not create any issues.
It still happens that an invoice is issued as fiscalized more than once—that is, the same invoice being fiscalized multiple times.
Answer – This issue was resolved with the deployment carried out on August 2–4, 2021. If you encounter any cases where the problem persists, please send us concrete data: NIPT, NIVF, and NSLF.
In principle, issuing invoices by the 10th of the following month is allowed only for ongoing services, such as telecommunications and construction. Meanwhile, there are certain types of activities—for example, professional service firms also need to close out the month or reconcile fees, hours, services, etc., in order to proceed with the corresponding invoicing. Will it be possible for invoices to be issued by the 10th of the following month for categories other than those mentioned above? In any case, we have identified the following method for issuing invoices for the preceding period(s) (see 3);
Answer – Currently, the system allows for this. The invoice must be issued in real time at the moment the supply is made, except in cases where the supply meets the legal criteria for a periodic supply and the invoice can be issued as a periodic invoice.
The Self-Care Platform and some software solutions have an active “VAT Effective Date” option with the alternatives (i) On the invoice date, (ii) On the delivery date, (iii) On the payment date. If an invoice or e-invoice is issued on August 10 by selecting the supply period 07/01/2021–07/31/2021 as well as the VAT option “On the date of delivery,” this sales invoice will be reflected in the Self-Care Platform in the transactions/statement for the July period; consequently, it will also be manually entered in the books for July. How should this invoice be recorded during this transitional period in the July books in the C@ts system, when the invoice date is 08/10/2021, but the supply period, VAT charge, and display of the supply occur during July, since the C@ts system does not accept an invoice dated August when loading the July books? Can the invoice date be set to July 31, 2021?
Answer – Regardless of the invoice date, the recording is made for the period in which the supply was completed.
The Self-Care Platform and Software Solutions do not allow Quantity or Price to have more than two decimal digits, resulting in unnecessary rounding that causes many problems when inaccurate invoices or e-invoices are issued. Why is it not allowed to set more than two decimal digits?
Answer – The taxpayer can resolve the issue by adding a line at the bottom of the invoice labeled “Reconciliation,” entering the value of the discrepancy, thereby matching and equalizing the amounts between the customs declaration and the invoice you issue in the Self-Care portal. The amount added for reconciliation cannot exceed 99 Lek. After that, you can proceed with the invoice's fiscalization.
Regarding the reflection of imports on the Self-Care Platform and their confirmation according to the DPT's instructions, Within three days, given that there are still many issues with data transfer and not all imports appear in real time or don't appear at all, wouldn't it be better to confirm the imports and complete the items during the month of their entry in the books, up to the 10th of the following month?
Answer – According to legal provisions, fiscalization must be completed within 72 hours; during the transitional phase, manual filing is also permitted outside this time frame in e-filing.
The Self-Care Platform and Software Solutions do not explicitly define VAT-free invoices under Article 24 of the VAT law for supplies to taxable persons abroad. Currently, a VAT code “Exempt supply” has been added in some software, but it still isn't listed separately in the Platform. Given that the VAT guidelines explicitly state that these invoices must include the article number (24.1) on the invoice, will this VAT code be added? At this moment, these invoices appear under exempt sales rather than under non-VAT sales, implying partial VAT credit as well as other tax implications.
Answer – When filing the sales books return, the taxpayer must reallocate the amount, accurately specifying where the sale should be reported.
If invoices are issued outside the hours specified in the platforms/software due to technical issues, heavy load, or human error, does this constitute grounds for a risk analysis by the Tax Administration?
Answer – Every taxpayer must strictly apply the legal framework and update the data on the place of activity in the Self-Care Portal.
By following all instructions and/or training from the Tax Administration, this new system has been designed so that for every purchase an invoice must be completed. However, there are transactions, such as in the case of invoices from abroad, for which there is no need for self-billing/self-invoicing, as is the case with international transport or the transit of electricity, which until now, for tax purposes, have been entered directly into the purchase book, and it is incorrect under the current tax legislation to prepare a “self-invoice” for them. How are these entries accepted into the purchase books? Will they be added manually from outside without issuing a self-invoice? And what happens when the purchase books are generated directly by the Platform and synchronized with the C@ts system?
Answer – In such cases, an invoice issued by the buyer will be prepared.
During the transition period, when the sales invoice has an "unaccepted" status but has been paid at the bank, will it automatically appear in the sales book or be added manually? And when the recipient eventually accepts it, will it be added—duplicated—in the platform/software at the moment of acceptance?
Answer – A rejected invoice, once its status is resolved, will be considered accepted and recorded in the purchaser's purchase ledger, provided that payment has been made within the invoice's issue period.
Will consolidated invoices be allowed in the case of Tax Representatives registered for subscription services for non-taxable persons in Albania?
Answer – No, they will not be allowed. In this case the buyers are different, the payment is made by different individuals, and a consolidated invoice cannot be issued.
To our understanding, a series of actions related to the Fiscalization process must be carried out on the Self-Care Platform. Access to this platform is only possible through e-Albania credentials. e-Albania holds confidential information, and therefore we consider it essential to find an alternative solution to access the Self-Care Platform.
Answer – Access to the Self-Care platform will, for the time being, be provided only through the e-Albania portal for security reasons.
XXXXXXX is a construction company that builds apartment buildings (i.e., it acts as both the builder and the investor) and, under the VAT law, must issue a Sales invoice for the constructed building and also a VAT-free Purchase invoice for the value of the apartments built. Currently, the fiscalization system does not have a self-invoice or self-supply template in which the sale is treated as a taxable self-supply and the purchase is exempt (for the value of the building).
Answer – In such cases, two invoices will be issued by the buyer: one as a VAT-taxed sale and the second as a sale without VAT.
Also, there is a problem with paying electronic invoices if the buyer has issued an invoice in Euros, banks require that the settlement also be made in Euros at the invoice amount, even though the invoice carries the date's exchange rate, and we should have the right to settle the invoice in any currency in which the company holds funds.
Answer – As a rule, invoices will be settled in the currency in which they are denominated. Any other matter is an agreement between the parties.
Some purchase invoices appear under the Electronic Invoices – Purchase Invoices option, while under the Buy and Sell Book option, purchase transactions do not appear.
Answer – The inclusion of invoices in the respective books is an automatic process that takes place once a day, specifically after midnight, and the only condition invoices must meet to be included in the books is that they have been fiscally registered.
The banks (the law) require that the invoice be paid in its own currency, but this issue cannot be imposed on us, since the funds under management and the method of payment are matters agreed upon between the parties.
Answer – Invoices will be settled in the currency stated on the invoice (same as question no. 18).
The invoice format should also include a contact number or email address to communicate with suppliers in case of billing errors. The current format does not accurately display the email address, but the NIPT?
Answer – These details can be added to the “Notes” section.”
Source: General Directorate of Taxes.