Invoice by invoice: what data makes a VAT process controllable

01

The data that makes a VAT process controllable

A VAT process is controllable when every invoice issued contains the data required by Article 226: identification number, date, details of the supplier and the customer, quantity and nature of the goods or services, taxable amount per rate, rate applied, and the VAT amount due.

These elements make it possible to reconstruct the transaction and feed the VAT return, which must include all data needed to determine the tax due and the deductions to be made.

02

Why traceability starts with invoice data

The Directive requires every taxable person to keep accounts detailed enough to allow the application of VAT and its control by the tax administration.

Invoices, whether paper or electronic, must guarantee the authenticity of origin, integrity of content, and legibility from the time of issue until the end of the storage period, including through business controls that create a reliable audit trail.

03

How to build the process step by step

Steps

1. Collect the mandatory Article 226 data for each invoice: identifiers, dates, quantities, taxable amount, rate, tax.
2. Check whether the recipient's agreement is needed for electronic invoicing, subject to exceptions set by the Member State.
3. Ensure authenticity, integrity, and legibility of the invoice through documented business controls.
4. Archive copies of invoices issued and received, making them available to the administration upon request.
5. Report the aggregated data in the VAT return within the deadline set by the Member State.

04

A reconstructed example (hypothetical)

Hypothetical example: a company selling machinery applies the reverse charge to an intra-Community supply. The invoice includes the wording 'reverse charge', the buyer's VAT number, the quantity of goods, and the taxable amount per rate, as required by Article 226.

These elements, together with electronic archiving of data that ensures authenticity and integrity, make it possible to reconstruct the transaction in case of an audit.

05

Document control checklist

• Invoice identification number and date present and consistent.
• Supplier and customer details complete, including VAT number where required.
• Taxable amount, rate, and VAT amount calculated for each applicable rate.
• Authenticity, integrity, and legibility of the invoice ensured until the end of the storage period.
• Copies of invoices archived and accessible on request by the administration.

06

How to set up software to support this control

• Define a role responsible for verifying invoice data before accounting entry.
• Configure fields matching the Article 226 requirements for each invoice issued.
• Set up an archive log tracking location, format, and accessibility of invoices.
• Set up a periodic review checking authenticity and integrity before the VAT return.

07

Quick clarifications

• Accounts must be detailed enough to allow VAT control by the tax administration.
• The VAT return must contain all data needed to determine tax due and deductions.

08

Next operational step

The useful next step is to map, invoice by invoice, which Article 226 fields are already collected by the management system and which require additional manual checking before archiving.