PERU SUNAT PUBLISHES E-INVOICING MANDATE FOR ALL MULTINATIONALS

Peru published new legislation on August 3, 2015 that mandates electronic invoicing as the standard starting in 2016.  Over the last few years, the SUNAT (Peru’s Tax Authority) has announced a number of e-invoicing waves; however, this latest legislation focuses exclusively on large and medium organizations classified as PRICOS (principal contribuyentes nacionales).

Below is the key information on the Peru mandate:

Name of mandate: Resolucion de Superintendencia de la SUNAT 300-2014

Important Dates:

Electronic Invoicing - Comprobantes de Pago Electronicos (CPE):

• 1st wave: October 1, 2014 for 239 companies [Published 2013]
• 2nd wave: July 1, 2015 for 778 companies [Published Sep 2014]
• 3rd wave: July 15, 2016 of all PRICOS  as of July 31, 2015  [Published August 3, 2015]
• 4th wave: December 1, 2016 for those taxpayers that as of July 31, 2015 have:
  • The capabilities of a principal contribuyente  of the intendencia of Lima Peru
  • The capabilities of principals contribuyentes of the regional and municipalities

All multinational companies should be included in the 3rd wave with a deadline of July 15, 2016. If you do not know if your organization is designated PRICO, check with the SUNAT immediately.

The above information is published on the SUNAT website athttp://www.sunat.gob.pe/legislacion/superin/2015/203-2015.pdf.

Requirements

• Electronic Documents: Electronic Invoices, Boleta de Venta Electrónica (end consumer), Credit Note, Debit Note, Daily Summaries, Comunicación de Baja
• Outbound:  Sending Invoices to customers – These must be approved by the SUNAT and approved with aCDR (constancia de recepcion).
• Inbound: Ability to receive invoices electronically from suppliers.
• Certification Process (Proceso de Homologacion): Testing phase must be completed within 25 days.
• Contingency:  Will be used when the systems online is unavailable due to updates and maintenance.
• Storage:  Documents must be stored for 4 years.
• Cancellations:  Applies to all electronic documents. You have up to 72 hours after receiving the CDR from the government.
• Daily Summaries:  For contingencies and cancellations
• Guia de Remision or Guia de Transportista: Document must be on truck and approved by government. Typical process for many companies is to ship with the Factura and the Guia de Transportista on the truck.
  • Libros PLE Mandatory Reports Electronically:
    • Compras (Purchases)
    • Ventas (Sales)
    • Libro Diario (Daily ledger)
    • Libro Major (General ledger)

As part of go-live, an organization needs to make their readiness declaration.  The requirements include:

• Check if invoices, boletas de ventas, credit and debit notes, daily summary and contingencies are within the standards of the SUNAT
• Both the electronic and paper documents must pass the certification process
• Once Successful completion of the test, the SUNAT will issue a Resolucion de Intendencia (R.I)

Note: you can’t be live in Peru without the R.I. The legislation states that once you start the testing process you have 25 days to complete the process or you will be asked to start again. This means that having a provider that works with you through certification is critical.

From a timing perspective, keep in mind that you will not want to go live with electronic invoicing during a fiscal period as switching over from a manual to electronic invoicing may impede your accounting processes.

You will run into a lot of vendors in Peru, and many will say they can support compliance. So ensure you understand the entire process or you will find yourself with operational issues, IT support issues, and at risk for audit penalties.  Remember this is as much a project management issue and SAP ERP issue as it is a web service integration issue. Make sure your providers solve the SAP configuration issues, theLibros reporting extracts, the web service integration and the assistance and management of your certification. 

Source: Peru SUNAT Publishes E-Invoicing Mandate for All Multinationals