In Article 17, point 1.3 It is discussed as an additional activity.. Exchange offices handle collections and payments on behalf of third parties; the transaction can be split between a cash payment and an exchange for part of it. They also collect payments for third parties with or without commissions. In the future, exchanges will be made using debit/credit cards. The question is how it will be implemented and how many invoices need to be issued for these complex actions?
AnswerArticle 17, paragraph 1.3 deals with additional activities, and the taxpayer, when carrying out more than one activity at the same place of business, is required to do so through the central invoice platform, to submit the data for the main activity, namely the activity that generates the highest revenue at that place of business, and also to provide the data for the other activities it carries out as ancillary activities.
Invoices must be issued by service, since even today currency exchange offices do not perform transactions on a single invoice or coupon. The invoice for the currency exchange transaction will be a separate invoice and will refer to Article 24 of Instruction No. 16, dated April 3, 2020, “On the Invoice and the System for Monitoring Turnover.”
In Article 17, point 1.11.. This is about the schedule. Offices have different hours, official closing time, Bank of Albania It requires all other actions by 3:00 PM; BOA says they will be processed the next day. In the future, many offices will switch to 24-hour service.
AnswerOn the central billing platform, the portal Self-Care The schedule can be set according to the needs of the currency exchange offices, even 24 hours in advance, as stated above.
Article 18. Operator Registration. How will it be implemented when we hire employees? part-time Because in general, many offices even today only have employees on Saturdays and Sundays.
AnswerThe system will work the same way, even though they will be a part-time employee; they will be registered as an operator in the system, on the platform. Self-Care.
In Article 20. Recording invoices in the sales book and the purchase book Point 9 and point 13 state that there will be a Sales Book – for sales and a Purchase Book – for purchases. These will be generated by the system at the end of the month. How will this be applied to exchange offices? In exchange offices, the Sales Book is the difference between purchases and sales, and the Purchases Book records purchases that serve the business, such as paper, ink, energy, wire, etc.
Answer Problems arise from discrepancies in the obligations arising from exchange invoices due to non-timely returns, but also for other reasons:
Deadlines are often not respected by banks and businesses. Failure to return on time As in the law and in the UMF, there is a specified time limit and it does not allow for any delay for any reason.
Also, besides The return is delayed, and the change in obligation occurs., e.g.: being charged in LEK by the exchange invoice and converting them back into EURO.
How will we handle currency-to-currency conversions? The Bank of Albania does not accept them and, according to its regulations, any exchange that cannot be converted into its lek equivalent must be carried out under the law. Therefore, UMF must issue three exchange invoices for a currency-to-currency transaction.
AnswerIt turns out that there are no restrictions on currency-to-currency conversions, and the Bank of Albania is the licensing and monitoring authority, and the statement “The Bank of Albania does not accept and makes it mandatory” is not correct.
As far as fiscalization is concerned, there are not three invoices for currency-to-currency exchanges but two currency purchase and sale transactions, which can be structured and linked as transactions by the programs that will be on the market.
How can I issue an exchange invoice when I don't have any cash on hand?
AnswerCash register transactions are specified in Article 40, "Procedures for Registering Cash Transactions," for cash payments.
Will our invoice have “Approved” or “Not Approved”?
AnswerInvoices will not require approval since they are not electronic invoices but rather cash transaction receipts. In the case of electronic invoices, the approval or rejection process is defined.
What are we going to do about the open positions?
AnswerIt is not related to the invoicing and fiscalization process.
How should we proceed if the client's irrevocable request is to modify or later cancel the invoice?
AnswerIn all cases, an invoice will be issued, and in cases of errors or returns, a corrective invoice will be issued.
We have a vault that serves as an exchange office. Does UMF mean a vault for each operator? How should we proceed?
AnswerThe number of cash registers and operators is not limited but is managed by the software that will be used by the currency exchange offices.
Does the law set a maximum fixed cash balance? What should we do in this case when our business is licensed to handle physical cash transactions? This penalizes us in fulfilling the customer's request in both time and quantity.
AnswerThere is no specified limit on the maximum fixed condition of the ark in the law.
Will there be additional costs for the business activity? How are we supposed to be compensated?
AnswerThere will be no additional cost to the business.
Source: General Directorate of Taxes.
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