Topic of the discrepancy
Failure to share invoices (B2C) with the Authority within 24 hours after issuance
Why could you get this intimation from ZATCA?
This notice is sent if ZATCA comes across invoices where the reporting time is more than 24 hours after the issue time of the invoice. ZATCA is analyzing your e-Invoice data to identify invoices that are reported after 24 hours of issuance.
Which ZATCA regulation does it refer to?
According to E-invoicing implementation resolution ,Simplified Tax Invoices and their associated Electronic Notes must be reported to the Authority within a period which must not exceed 24 hours from its generation
How can you check and respond?
Check your e-Invoice reports and calculate the time difference between submission time and issue time. Identify the instances wherever this difference is greater than 24 hours. The times and time difference can be directly obtained in ClearTax reports. You can request ZATCA to share sample instances of violation to identify patterns and fix.
Topic of the discrepancy
Duplicate in one of the technical identifiers (UUID, Hash, IRN, ICV, QR)
Why could you get this intimation from ZATCA?
The same technical identifier(s) has been used in multiple invoices submitted to ZATCA. It could be duplicates in one or more of the technical identifiers in the invoice xmls
Which ZATCA regulation does it refer to?
1. Invoice identifier IRN- A unique identification of the Invoice. Invoice Reference Number (IRN)
2. Invoice UUID - Universally Unique Invoice Identifier in UUID format.
3. Invoice Hash - The base64 encoded SHA256 hash of the invoice. This hash will be computed from the business payload of the invoice.
4. ICV - Invoice counter value. Invoice tamper-resistant counter value
How can you check and respond?
1. Download reports of e-Invoices to check the technical identifiers
2. Alternatively run queries on your invoices to identify duplicates in unique technical identifiers
Topic of the discrepancy
Failure to add the correct buyer or seller address in the invoice
Why could you get this intimation from ZATCA?
The values given as address of buyer/seller is incorrect and contains generic characters. The address fields don’t contain genuine address values.
Which ZATCA regulation does it refer to?
According to the E-invoicing implementation resolution, Buyer/ Seller Name & Address should be as per the provision mentioned in Article 53(5) of the VAT Implementing Regulation.
How can you check and respond?
1. Check e-Invoice reports to identify if any address fields have been passed as ‘NA’, special characters or generic values
2. Perform the check on both buyer and seller addresses
3. Request ZATCA to share a few samples of wrong address to identify patterns
Topic of the discrepancy
Incorrect details in CSR during device onboarding
Why could you get this intimation from ZATCA?
This discrepancy is highlighted if the fields used during onboarding devices are wrong with random values which are not the right information as per the location and business.
Which ZATCA regulation does it refer to?
As per Onboarding Developers Guide, the CSR contains information the ZATCA authority will use to create CSID. These inputs contain fields relating to Common Name, Organisation unit name , Organisation Name , Country Name etc.
How can you check and respond?
1. Check whether all the mandatory , conditional & optional fields are available in your EGS during registration
2. Verify the sample xmls used in compliance check
3. Check whether the details provided during CSR Generation belong to the branch/Organisation for which device is being onboarded.
Topic of the discrepancy
Non-compliance with the implementation of phase 2 e-invoicing
Why could you get this intimation from ZATCA?
ZATCA expects taxpayers to start submitting phase 2 e-Invoices as per the timeline prescribed for an enterprise. If you are not generating compliant phase 2 invoices by that timeline or are not continuously generating phase 2 e-Invoices then this discrepancy is highlighted by ZATCA.
Which ZATCA regulation does it refer to?
As per Detailed Guidelines for E-invoicing , the taxpayer must generate a Tax Invoice includingadditional data fields prescribed in the Annex 2 of E-Invoicing Resolution in an electronicformat using a compliant E-Invoice Generation Solution (EGS) which is Onboarded .Phase 2(Integration Phase) Tax Invoices must be generated in XML format or a PDF/A-3 (withembedded XML).
How can you check and respond?
1. Check whether you have started integrating your e-invoices within the timelines prescribed by ZATCA.
2. Check that there are no breaks in e-Invoice generation and submission after go-live with phase 2
3. Check whether you are fulfilling the visibility conditions on the visual representation as mentioned in the annexure 2 of the e-invoice implementation resolution.
Topic of the discrepancy
Missing or incorrect ‘Commercial Registration number’
Why could you get this intimation from ZATCA?
‘Commercial Registration number’ of buyer or seller is either omitted or incorrect in invoices where it is expected. ZATCA is comparing the CRs used during e-Invoice generation with the complete list of active CRs.
Which ZATCA regulation does it refer to?
According to E-invoicing implementation resolution , Additional seller IDs. One of the following IDs must be entered:
1. Commercial Registration (CR)
2. MOMRA License
3. MLSD License
4. SAGIA License
5. Other ID of the seller.
It consists of:
1. Type of ID
2. ID Number Note:
If the CR is chosen and in case of multiple commercial registrations, the seller should fill the commercial registration of the branch in respect of which the Tax Invoice is being issued. In case multiple IDs exist then one of the above must be entered following the sequence specified above.Additional buyer ID if the buyer is not VAT registered. One of the following IDs has to be provided:
1. Tax Identification Number (TIN)
2. CR
3. MOMRA License
4. MLSD License
5. 700 Number
6. SAGIA License
7. National ID
8. GCC ID
9. Iqama Number
10. Passport ID of the buyer.
It consists of:
1. Type of ID
2. ID Number In case multiple IDs exist then one of the above must be entered following the sequence specified above.
How can you check and respond?
1. Audit a few sample invoice xmls to check if correct buyer/seller CRs are present in the invoice data
2. Check whether the CRNs for the respective branches have been sent to ZATCA
3. Verify for all the invoices by checking the downloading the e-Invoice reports