This is how AFIP changed the rules of the game for supermarkets

The AFIP It put into effect a new instrument that will complicate the lives of supermarkets, by not allowing them to adjust the current accounts of their suppliers as they did up to now.

These are the new rules on debit and credit notes, which from the entry into force of General Resolution 4540 of AFIP can only be issued by the seller.

The debit and credit notes are used to adjust the sale price when there are discounts, bonuses, deductions, returns, cancellations, interests, exchange differences, among other situations not foreseen in the original invoice.

In supermarkets, health companies, food and beverage distributors, among other activities, it was these companies that issued the adjustments to the supplier through debit or credit notes, explained Ezequiel Passarelli, from SCI Consultoría Integral Tributaria.

As this is the usual practice, now these companies will have to modify all the systems and accounting in the relationship between customers and suppliers, Passarelli emphasized.

And so, in addition, supermarkets will lose power to adjust the current account of thousands of monotributistas.

With this provision, the AFIP seeks to eradicate a custom that is verified in certain activities in which the buyer issues debit notes to adjust checking account It has with the seller, instead of waiting for the credit notes issued by the seller, thus avoiding duplication of vouchers for the same discount, said Hugo Benítez, of PwC Argentina.

Another highly relevant aspect that arises from the regulations is that debit and / or credit notes may only be issued as an adjustment for original operations. The consequence of this modification is that, according to the tax interpretation, these vouchers can no longer be issued due to adjustments of rejected checks, recovery of expenses, among other operations that today are standard practice in the market, Benítez pointed out.

When the discounts and / or bonuses are agreed and determinable at the time of issuing an invoice, and these are directly related to that voucher, these concepts must be applied in the original document.

“The intention of the AFIP in this regard is reduce the amount of vouchers issued in the event that the amount of the discount or bonus is known at the time of issuance of the receipt, “said Benítez.

When the debit or credit note is issued due to an adjustment linked to price and / or quantity differences between what is agreed by the parties, what is documented in the original receipt and what is actually delivered, the instrument must individually identify the invoice that adjusts, Benítez specified.

In addition, the measurement is important for the AFIP in commissioning of the Digital VAT book, whose implementation is being carried out gradually and is expected to be fully in force for all those responsible for VAT registration between the months of August and next September, Benítez said.

And, even, the specialist advanced, towards the pro forma VAT, by which taxpayers will be able to obtain the preliminary sworn declaration determining the tax, including also the withholdings and / or perceptions reported to the AFIP. This monthly affidavit will be subject to compliance by the person in charge, being able to make the adjustments that are considered pertinent.

With this provision, the AFIP seeks to eradicate a custom that is verified in certain activities

The ten keys to the instrument

Carlos Roca, from the Carlos Roca Tax Consultants and Auditors study, listed the ten keys to the new instrument that came into effect on July 1:

1. Who should issue the debit or credit notes?

Only the subjects that issued the vouchers for the original operations may issue the credit and / or debit notes.

2. For what concepts?

For discounts, bonuses, withdrawals, returns, cancellations, interests, etc.

3. Should there be a previously issued invoice?

Yes, they must always be related to one or more invoices or equivalent documents previously issued.

4. In which cases would the ND / NC issue not correspond?

When the discounts and / or bonuses are agreed and determinable at the time of the issuance of an invoice or equivalent document, and these are directly related to that voucher, these concepts must be applied in the original document that supports the operation.

5. Can I issue the ND / NC to another subject that is not the original receiver of the invoice?

No, they will be issued only to the same recipient of the original vouchers to modify the invoices or equivalent documents previously generated.

6. What should be indicated in the ND / NC?

The number of the associated invoices or equivalent documents or the period to which they adjust must be recorded, referencing the commercial data reported or linked to the original receipts, if applicable (eg, commercialized items, order notes, purchase orders or other non-related documents). adjustment tax issued between the parties, etc.).

7. what happens when the debit or credit note is issued by a adjustment linked to price and / or quantity differences between what is agreed by the parties, what is documented in the original receipt and what effectively delivered?

The credit and / or debit note must individually identify the invoice or equivalent document that adjusts, also referencing the commercial data consigned or linked to the original vouchers as indicated in the preceding paragraph.

8. Is there a deadline to issue the NC / ND?

The credit and / or debit notes must be issued within 15 calendar days from the occurrence of the event or situation that requires your documentation through the aforementioned vouchers.

9. What happens if the systems are not suitable for issuing the ND / NC?

Until the voucher issuance systems are adapted, in order to provide specific fields for the income of the period that is adjusted through the respective credit and / or debit notes, the information must be contained in the header of the document of fit or somewhere intended for legends or additional free entry data.

The news on the authorization of specific fields will be published on the microsites corresponding to the billing regimes available on the AFIP website.

10. What happens to the SMEs reached by the “Electronic Credit Invoice Regime”?

The same treatment will be applied when you must issue a proof of adjustment on an invoice or equivalent document issued prior to the implementation of the aforementioned regime. In the case of operations documented before July 1, 2020, for the calculation of the negotiable net amount of the executive title, only the credit and / or debit notes issued by the issuing subject of the respective electronic credit invoice will be considered.

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