The exact reason of the unexpected shutdowns of a national tax administration system is unknown. You may assume that the professionals involved take all reasonable efforts to make sure that the number and duration of these events should show a steadily declining trend. Leaving the responsibility for that major task to the authority, let us now take a look at the responsibilities and actions the management of tax authority malfunctions entails for the taxpayers.
If a breakdown occurs, the exemption from the NAV Online Invoice data reporting of the taxpayer's is only temporary
1. The most important thing is that, if any system shuts down:
- either the company's invoicing system,
- or the tax administration system or
- the communication channel between them
the company will only be provisionally, temporarily exempted from the obligation to supply data on invoices. The exemption only lasts until the systems return to normal operation.
2. You can only maintain the malfunction of your own invoicing system for a few days without providing data.
3. It is always the responsibility of the taxpayer to detect malfunctions in the tax authority operation and to deal with their consequences. Considering that a malfunction is an unexpected event, what distinguishes it from a downtime is that you cannot be prepared for it, thus the challenge is even greater.
4. Looking at the relevant NGM Decree, you find that you can be informed about the malfunctions of the NAV Online Invoice System and their successful elimination through the website of the Online Invoice System.
The Decree also states that you must submit the missing data within 24 hours of the elimination of the malfunction. It is important that the Decree stipulates 24 hours and not 1 working day.
5. If the restart of your stopped NAV Online Invoice reporting also requires the involvement of some technical staff, the 24-hour deadline can only be met in all circumstances if the necessary technology services and resources are also available on weekends and public holidays.
6. The 24 hours for the subsequent supplementation of data supply start from the official notification of the elimination of the breakdown which may require regular monitoring of the NAV Online Invoice portal, sometimes beyond working hours. It may also be appropriate to appoint a responsible person within the organization to perform the necessary checks after the restart to ensure that all reportable invoices have actually reached the system of the tax authority.
7. When any news of a malfunction of the NAV Online Invoice system is released, it is a natural reaction and we often find in practice that companies decide to temporarily stop their outgoing invoicing. With this measure, they intend to reduce in advance any subsequent inconvenience caused by the malfunction. Undoubtedly, the solution can work if invoicing can be delayed and if the additional administrative costs of time-shifting invoicing and the subsequent realization of revenues are commercially tolerable.
8. Of course, all these issues do not arise if the invoice reporting solution used is prepared to deal with regular or prolonged downtime and malfunctions of the tax authority. Outsourcing the implementation of online invoice data supply to an external service provider can be an effective solution. In this case, the responsibility for managing the data supply and the related external malfunctions, as well as the resource and expert requirements of the tasks, are also outsourced to the partner at the same time.
Our cloud-based Connectax Invoice Reporter service is continuously available despite the malfunctions of the NAV Online Invoice System. Our trained support team behind the solution offers a realistic and competitive alternative for ERP system users, in particular, if their built-in online invoice reporting solution is not prepared for the ‘stress test’ generated by the breakdown.