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Eduo

(ENGLISH) SAFT, Billing Certification and PDFs

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Eduo

Hello, all.

First of all I want to apologize for this post in english. My portuguese is OK for reading but it's very bad for writing or speaking. I've been a longtime lurker of the forum, since I've had to support projects based in Portugal for a long time in my last two companies.

I'd understand if you don't feel like answering in a different language and I'd also be OK if you can only help me with an answer in portuguese.

I've tried solving this problem by going to many places, but portugal-specific forums are understandably not generally available in other languages :)

---

My question is related to billing system certification and PDF generation, in regards of generation of "originals" and "duplicados". I've seen lots of discussions on this subject in this forum but no clear guideline or confirmation from the AT of how exactly to procceed (also, a lot of the discussions are prior to changes in 2015, so I'm not sure how much they apply).

As you probably know if you're reading this subject title, current VAT legislation requires invoices to be printed in duplicate, with an original sent/printed to the client and a duplicate stored for archiving.

I can't find anywhere on the legislation that says these two copies should be labeled different and every person I ask tells me "how would you distinguish them otherwise?", but they can't explain why they should be distinguished.

The legislation also isn't clear whether the rules apply to any time of invoice but it sounds like it's designed for printed invoices, since the requirement makes no sense for PDFs or Electronic Invoicing (EDI).

(keep in mind I come from a country where invoices are only informative documents, can or not be printed, don't require any duplicates or print version tracking and PDFs have no requirements to be valid, since all data is handled electronically with the local AT, reported daily and flagged automatically if there're discrepancies).

So, in my case I have a system that produces a single invoice PDF. This PDF is sent or printed to the customer and also stored for archiving.

My tax person believes this can't work for certification, and we should be storing at least TWO different PDFs. One that says "original" and one that says "duplicado". To me this sounds wrong in all possible levels and is also incredibly complex to implement in the system we're trying to certify. I don't think it's technically justified but I understand it may be a requirement that made sense for printing in the past.

In my experience with billing certification, I was able to certify a system that produced a single PDF which we sent and also stored, but it was right before the 2015 modifications (Portaria n.o 338/2015) which insists: 

A fatura, o recibo e a fatura-recibo são emitidos em duplicado, destinando-se o original ao cliente e o duplicado ao arquivo do titular do rendimento.

(this reinforces the ambiguous note that's been present for over 30 years in the Codigo de IVA:

4 — Os documentos referidos nos números anteriores devem ser processados em duplicado, destinando-se o original ao cliente e a cópia ao arquivo do fornecedor.

)

So, I ask for your help: Is there a definitive answer on whether specially labeled duplicados is really a requirement for the AT? If the answer is "YES" then is there a definitive answer on whether this is a requirement for invoices produced and stored in PDF?

Do I need to produce two different PDFs and store one labeled "Duplicado"?

If yes, can I just print the original for the customer and not print at the same time the duplicado, only store it as a PDF file? 

If yes, can I just store the original and produce the "Duplicado" on the fly if it's ever necessary by adding the label or does the PDF need to be generated at the same time?

In all cases, we're talking about a SAFT-compliant billing system, with the SAFT digital signature properly generated and included in the invoice and records. The question is only about invoice design and PDF generation logic.

I would want to avoid having to produce multiple, different PDF files, avoid printing and storing duplicados.

Lastly: I'm talking about standard read-only PDFs. I don't know if any of the questions above change if the PDF is not digitally signed, but ours currently aren't.

I deeply thank any of you that can answer and truly apologize if anyone feels offended or annoyed by this post in english. I've tried for a long time to avoid having to do this because I understand how inappropriate it is, but other alternatives have proven ambiguous or useless (especially consultants we've hired, who, frustratingly for us, have been unable to provide a clear answer).

Edited by Eduo

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Rui Carlos

You should probably ask your question here: https://www.portugal-a-programar.pt/forums/topic/57541-saft-pt-debate-de-dúvidas-e-ideias/

Anyways, from what I remember people talking, I think "Duplicado" mark should be present.  However, I don't see why you should store both versions, as the original it to be sent to the customer, and only the duplicated is to be stored.

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Eduo
On 12/22/2017 at 7:26 PM, Rui Carlos said:

You should probably ask your question here: https://www.portugal-a-programar.pt/forums/topic/57541-saft-pt-debate-de-dúvidas-e-ideias/

Anyways, from what I remember people talking, I think "Duplicado" mark should be present.  However, I don't see why you should store both versions, as the original it to be sent to the customer, and only the duplicated is to be stored.

Hi, Rui

I had asked the AT. It took them three weeks to reply (arrived last week). The only thing they clarified is that if I print invoices, I should have a "duplicado", but didn't clarify if the "duplicado" needs to be labeled differently or if just having and identical copy would be enough.

They also didn't answer if I needed to print it at the same time, if I could have it as PDF or if I could just add the label to an "original" unlabeled invoice.

I've asked them again, a couple of days ago. If history serves it won't be very useful either.

Thanks for your reply!

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jacPereira

Also, pay attention to the fact that if the customer uses the PDF and not it´s print version for archive, the document is not considered legal for deducting IVA without electronic signature.

You may print the original and duplicate to the same PDF, if it´s for paper printing. If the PDF is only for signing and archive it´s enough the original because the client will receive the same document that you archive (both original...).

Another boring thing is the "reprint" of the original... it must complain to the legend "2. VIA" and mention "Documento conforme o original" (This document conforms to the original) You can't reuse the original and all usage needs to be logged.

Well... that´s what's written... but what I see is PDFs without signature (even from public entities) that we print and that´s all. I think nobody cares about. Even for certification they normally ask you for a PDF copy of the documents for their archive.

I hope that this won't bring more confusion to your doubts...

 

(Além disso, preste atenção ao facto de que, se o cliente usa o PDF e não a versão impressa para o arquivo, o documento não é considerado legal para deduzir IVA sem assinatura eletronica.
Pode imprimir o original e o duplicado para o mesmo PDF, se for para impressão em papel. Se o PDF é apenas para assinar e arquivar é suficiente o original porque o cliente receberá o mesmo documento que voce arquivou (original ...).
Outra coisa aborrecida é a "reimpressão" do original ... deve conter a legenda "2. VIA" e mencionar "Documento conforme o original" pois não pode reutilizar o original e qualquer acesso para impressão do documento arquivado deve ser logado.
Bom ... é o que encontrei escrito ... mas o que vejo na realidade são PDFs sem assinatura (mesmo de entidades públicas) que imprimimos e já está. Acho que ninguém se importa. Mesmo para a certificação, normalmente pedem uma cópia em PDF dos documentos para o arquivo deles.
Espero que isto não traga mais confusão às suas dúvidas ...
)

jacPereira

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