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Nothing stops you from using the "...or more series" part to generate numbers that are specific to the day, the hour or, if you feel like it, the minute. Today

by d_k_f 5y ago

Nothing stops you from using the "...or more series" part to generate numbers that are specific to the day, the hour or, if you feel like it, the minute. Today's first invoice could be 2021-07-16-001, the second one 2021-07-16-002, etc. If you really don't want people to be able to guess your invoice volume from numbers alone, there are various ways to do that while still being compliant to EU laws.

zimpenfish 5y ago
I think e.g. 2021-07-16-123 followed by 2021-07-17-001 wouldn't fall under "sequential number" though because, well, they're not sequential. The Italian authorities seem to see this the same way - https://vatdesk.eu/en/eu-vat-news/italy-mandatory-mentions-on-invoice/ https://vatdesk.eu/en/eu-vat-news/italy-mandatory-mentions-o... (Annoyingly the directive doesn't give a definition for "a sequential number" itself.)
- d_k_f 5y ago
  They are sequential for all intents and purposes, they are simply using two separate series within the same number – you are perfectly able to determine the order of the invoices. I do agree that (as is so often the case) the directive is not specific enough to determine whether the Italian interpretation is correct or not, though I can provide some context from the German side as provided by the ministry of finance: "Eine lückenlose Abfolge der ausgestellten Rechnungsnummern ist nicht zwingend"[1] (~ "it is not required for the invoice numbers to be gapless"), which directly contradicts the Italians as far as I understand it. [1] https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Steuerarten/Umsatzsteuer/Umsatzsteuer-Anwendungserlass/Umsatzsteuer-Anwendungserlass-aktuell-Stand-2021-06-28.pdf?__blob=publicationFile&v=47 https://www.bundesfinanzministerium.de/Content/DE/Downloads/... - p. 522, 14.5 (10) 4
  - zimpenfish 5y ago
    > you are perfectly able to determine the order of the invoices. But you can't determine if there are any gaps which is what the Italian ruling seemed to be concerned with (as best I could follow the Google translation which was pretty bad) and the Germans aren't bothered about. I think if it were me, I'd ere on the side of caution and have them be sequential (ordered, gapless).

by d_k_f 5y ago

zimpenfish 5y ago

I think e.g. 2021-07-16-123 followed by 2021-07-17-001 wouldn't fall under "sequential number" though because, well, they're not sequential. The Italian authorities seem to see this the same way - https://vatdesk.eu/en/eu-vat-news/italy-mandatory-mentions-on-invoice/ https://vatdesk.eu/en/eu-vat-news/italy-mandatory-mentions-o... (Annoyingly the directive doesn't give a definition for "a sequential number" itself.)

d_k_f 5y ago
They are sequential for all intents and purposes, they are simply using two separate series within the same number – you are perfectly able to determine the order of the invoices. I do agree that (as is so often the case) the directive is not specific enough to determine whether the Italian interpretation is correct or not, though I can provide some context from the German side as provided by the ministry of finance: "Eine lückenlose Abfolge der ausgestellten Rechnungsnummern ist nicht zwingend"[1] (~ "it is not required for the invoice numbers to be gapless"), which directly contradicts the Italians as far as I understand it. [1] https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Steuerarten/Umsatzsteuer/Umsatzsteuer-Anwendungserlass/Umsatzsteuer-Anwendungserlass-aktuell-Stand-2021-06-28.pdf?__blob=publicationFile&v=47 https://www.bundesfinanzministerium.de/Content/DE/Downloads/... - p. 522, 14.5 (10) 4
- zimpenfish 5y ago
  > you are perfectly able to determine the order of the invoices. But you can't determine if there are any gaps which is what the Italian ruling seemed to be concerned with (as best I could follow the Google translation which was pretty bad) and the Germans aren't bothered about. I think if it were me, I'd ere on the side of caution and have them be sequential (ordered, gapless).