• Will we have a different recipient code for each supplier?

The recipient code identifies the recipient, therefore it will be a unique code for your company, which you will have to communicate to all your suppliers to include it in their invoices; this will allow you to receive them through the DocFlow channel (as intermediary). If there is a management need to separate invoices by supplier, this may be a specificity that is implemented according to your needs and should not involve the recipient code.

• Will the recipient code be communicated to us by our customers?

You will need to request your customers resident or with permanent establishments in Italy to provide you with their recipient code. In case of absence of such code, you can send them the active invoices through SdI by valuing the recipient code to "0000000" and entering the PEC address with the appropriate tag in the document. The Exchange System will deliver your invoice via PEC.

• Can DocFlow provide the recipient code?

DocFlow will provide the recipient code to its customers already with the basic reception service.

• What happens if the sender misses the recipient and sends an active invoice to another intermediary/ another PEC box? Does SdI notice this?

It is not expected that SdI will notice the error, therefore the invoice will be delivered (if the recipient code or the PEC exists) even if, in fact, the Customer has never received it.

• Currently we already exchange active and passive invoices in EDI with some customers and with our parent company and proceed to their digital storage. How do you link these aspects with the regulations that will come into force from 1/1/2019?

Since January 1, 2019 the only valid method for invoicing between companies with permanent establishments in Italy is the XML invoice sent via SdI.
This means that you can also maintain the EDI flow but it must be in side by side with the XML one and in case of discordance is valid what reported in the XML. Being the XML a structured flow as much as the EDI, it is obvious that this last one can be completely replaced from the first one and to tend it will be (otherwise it means to create a useless overhead). As far as digital preservation is concerned, what will have to be preserved are the XML files (and the relative receipts) always and only in digital mode (since they are electronic documents). In any case, the management of EDI must be deepened case by case.

• The supplier can send an invoice in the absence of the recipient code. If so, how is this handled?

The supplier can send the XML invoice through the SdI Channel indicating the recipient code "0000000" and entering a valid PEC address. In this case the invoice will be delivered to the Customer through the PEC with sender the Interchange System. The supplier can also send the invoice indicating the recipient code "0000000" in this case the invoice is considered issued but not delivered and the supplier has the obligation to communicate to the customer the availability of the invoice in the reserved area of the AdE website through other channels (e.g. e-mail).

• How will billing to private individuals work? Do I deliver the hard copy to the customer and send xml invoice data to SDI?

If "private" means "final consumer", i.e. customer without VAT number, the method is as indicated: you deliver a paper copy (or even electronic, for example a PDF sent to the customer's email) and (even later) you send the electronic invoice in XML format to SdI. The Inland Revenue will make available to the final consumer all its invoices received by SdI, for this reason the final consumer is given the right to explicitly waive the receipt of the copy of the invoice.

• Are active invoices to be sent daily or can they be sent at a different frequency?

It is possible to establish a periodic frequency for the transmission of invoices via SdI, in analogy to what happens with the "traditional" methods. The only constraint is that the date of issue is prior to the date of transmission or coincident but never subsequent.

• In relation to the new billing method, does anything change for statements e.g. VAT? Spesometer?

The expense meter will be limited to invoice data that are not transmitted through the ISS (e.g. foreign invoices). The transmission will be monthly. VAT declarations will be simplified for small companies (pre-filled declarations) and probably extended to all taxpayers in the future. It is easy to predict that when the system is fully operational, the requirements for declarations related to billing data will disappear.

• In the .xml data flow, in addition to the billing data, can there be data requested by the customer, such as order number and goods receipt?

XML contains some management tags, which are optional and the use of which can be agreed between the parties. Therefore I confirm that data requested by the customer may be present. This is in addition to attaching a file (PDF or other format) to the XML invoice, this file typically contains additional management data. The file limit is always 5 MByte.

• Electronic invoicing covers both active and passive invoices. Do you confirm?

Of course, the 2018 financial law provides for the obligation to issue electronic invoicing and transmit it through the SdI channel to all residents or permanent establishments in Italy. Only flat-rate or advantageous taxpayers are excluded from this obligation. The obligation applies to active invoices issued to residents or permanent establishments in Italy. Therefore, each company resident in Italy will receive passive invoices from its Italian suppliers (or with permanent establishments in Italy) in XML format through the SdI.