Guatemala is following the growing tendency to require electronic billing from economic operators. Thus, in April 2018, the Directorio issued regulations on the so-called “Electronic Invoice Online” (FEL), and agreed to the progressive implementation of this regime in order to reduce costs and time and provide more transparency and legal security to business operations.[i]
Unlike traditional electronic invoicing, this system establishes that all the management of tax invoicing in Guatemala must be carried out within the Superintendency of Tax Administration (SAT), prior to authorization and issuance of said documents.
Entry into force
Although the regulations were approved in April 2018, today their application is not mandatory for all taxpayers, and the FEL will be gradually implemented.
For these purposes, the SAT is currently sending notifications to taxpayers identified as special (large companies), stipulating that by December of this year (2019) they must have migrated to Online Electronic Billing. For the rest of taxpayers, a maximum term of 4 years is expected.
In any case, taxpayers who so wish, may voluntarily apply for the FEL Regime, for which they will have a maximum period of six months for the use of current authorizations of other means or forms of issuance of tax documents.
The purpose of this regime includes the issuance, transmission, certification and preservation by electronic means of invoices, but also includes exchange invoices, credit and debit notes, receipts and other documents authorized by the SAT for the FEL Regime.
This is intended to ensure greater control and security in the issuance of documents with tax implications, which must always have online authorization. In this sense, it is important to emphasize that the FEL system will be the sole way allowed in Guatemala for the issuance of tax documents.
Elements of the process
- Issuer: Issues the electronic invoice or other electronic tax documents (DTE).
- Certifier: Entity authorized by the SAT to review and certify the electronic invoices issued by the issuer.
- SAT: Verifies and receives the electronic invoices and other certified tax documents and validates them.
- Receiver: Receives invoices or other tax documents (buyer of goods or services).
Online Electronic Invoice work-flows
- The issuer or taxpayer issues the DTE or Electronic Tax Document and sends it to the certifier automatically.
- The certifier or the individual or legal entity that carries out the certification receives, validates, and authorizes each invoice and automatically sends it to the issuer and the SAT.
- The issuer delivers the invoice to the receiver.
- The SAT verifies and validates each electronic invoice and makes it available to the issuer.
- The recipient receives the invoice.
In short, the mandatory implementation of the Online Electronic Billing scheme obliges operators in Guatemala to review their processes and adapt their accounting and fiscal management systems, in order to guarantee compliance. It is, therefore, time for each company to review of their status with expert advisors in these areas, especially if the notification of the SAT has already been received for their migration before December of this year.
[i] SAT Directory 13-2018: http://www.minfin.gob.gt/images/downloads/leyes_acuerdos/acuerdodir_sat020518.pdf