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The result is a fragmented and fast-moving compliance environment that requires continuous monitoring.
Keeping pace with those developments is becoming increasingly demanding for tax leaders, particularly as regulations continue to evolve rapidly. Global operating structures can add another layer of complexity. Many technology companies, for example, are headquartered in the United States, where there is currently no domestic e-invoicing mandate, while global tax teams remain responsible for monitoring obligations elsewhere.
Luigi Bucceri, Principal , Indirect Tax, Ernst & Young LLP, notes that maintaining visibility across markets now requires sustained effort.
“Knowing what is happening is crucial, but it requires a great deal of knowledge transfer and effort,” he says. “It is important for tax leaders to subscribe to alerts, read articles and attend webcasts to stay informed.”
The operating models used by many technology companies also create challenges that differ from those faced in more traditional sectors.
Most jurisdictions currently mandate e-invoicing primarily for domestic business-to-government (B2G) and business-to-business (B2B) transactions involving locally established entities. Cross-border transactions and business-to-consumer (B2C) sales are often excluded. In many countries, non-established businesses remain outside the scope of mandatory e-invoicing rules, even where they are VAT registered.
This creates a complicated picture for technology companies, many of which primarily supply services cross-border and directly to consumers. Some businesses may have VAT registrations in countries operating mandatory e-invoicing regimes but no local entities. Others may conduct only limited in-scope transactions.
As a result, organizations may conclude that e-invoicing obligations do not materially affect them today, only to discover later that certain activities, jurisdictions or transaction types still fall within scope.
The challenge is that this position may not remain static for long.
In the European Union, for example, cross-border transactions between member states are expected to fall within mandatory e-invoicing requirements from 2030 under the VAT in the Digital Age (ViDA) proposals. That shift could significantly increase the number of technology companies required to comply.
Many of these developments point toward a more continuous and data-driven reporting environment over the remainder of the decade.
Bucceri cautions against assuming current obligations will remain stable.
“You can’t assume that what was true yesterday or is true today will be true tomorrow,” he says. “Legislation changes, business operations change.”