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Currently, the DES report (EU Sales list FR) is generated based solely on posted invoices and reflects the total invoice amount, regardless of the payment status. This means that the declaration is driven by billing data rather than actual cash movements.

Business requirement and gap:

In certain regulatory contexts, particularly where VAT is due based on cash accounting principles, the declaration period is determined by the moment the VAT becomes chargeable, which may depend on customer payment.

As a result, the current standard behavior does not fully address the following needs:

  • Consideration of partial payments in the declared amounts
  • Alignment of declared values with actual received payments
  • Accurate reporting in cases where invoices are settled over multiple periods

Impact:

Due to this limitation, users are required to:

  • Perform manual adjustments to the DES report
  • Reconcile invoice-based declarations with payment-based VAT exigibility
  • Accept a potential risk of inconsistency between accounting data and regulatory reporting

This increases operational workload and introduces compliance risks, especially in audit contexts where traceability between accounting entries and declarations is critical.

Suggested enhancement:

We recommend introducing an optional feature allowing calculation of DES amounts based on settlement transactions instead of invoice totals.

Such an enhancement would significantly improve compliance capabilities and reduce manual intervention.

We believe this improvement would bring strong added value for customers.

 

Category: Tax
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