Hello ZATCA team,
Let’s say the Supply Date is 25th March but it was forgotten to create an Invoice until 27th March (Issue Date).
In this case, which date will be chosen by ZATCA to recognize the VAT Liability?
Thank you !
cc: @Ankit.K.Tiwari
Hello ZATCA team, a quick follow-up on this thread please - thank you !
cc: @Ankit.K.Tiwari
@Yatin general rule for VAT due date is that VAT becomes due on earliest of 3 events:
- Supply date
- Invoice date
- Payment date
Which ever comes first. If payment is received before supply or issuance of invoice then a separate “advance payment tax invoice” has to be issued.
There are exceptions to the general rule such as continuous supplies, B2G supplies etc.. you will have to consult with tax team to understand VAT due date for such scenarios.
VAT Due Dates related provisions are stated in Article 23 of GCC VAT Framework Agreement https://zatca.gov.sa/ar/RulesRegulations/Taxes/Documents/GCC%20VAT%20Agreement.pdf
and Article 20 of KSA VAT Regulations https://zatca.gov.sa/en/RulesRegulations/Taxes/Documents/Implmenting%20Regulations%20of%20the%20VAT%20Law_EN.pdf
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@Ankit.K.Tiwari thank you. A related question - as the Invoice Date refers to the Invoice Issue Date here, is it safe to assume that backdating an invoice is not allowed?
Ex - A taxpayer today wants to backdate an invoice to 2 days ago to follow the business agreement. However, as the InvoiceIssueDate and InvoiceIssueTime need to capture the real time issuance (which is this moment today), backdating the invoice is not allowed. Additionally, the general ledger posting date in the ERP should match this invoiceIssueDate and InvoiceIssueTime.
This is also applicable to the credit and debit note. Is my understanding correct?
@Yatin as per the XML Implementation Standard, the only restriction related to Invoice issue date is that it cannot be in future, there are no other restrictions.
In general, taxpayers must follow their internal control policies regarding back dating of invoices and ZATCA cannot comment on internal policies of taxpayers.
Other commercial aspects ought to be considered, such as, customers may not accept invoices with unreasonable gap from current date which may reduce the time provided for exchange / return; reduce the time available for payment if sale was on credit; reduce time available for warranty, impact revenue recognition etc).
@Ankit.K.Tiwari thank you again. A quick follow-up:
With the example, that I want to issue an Invoice today 11 Aug 2025 with the IssueDate as 10 August 2025; what should I set the IssueTime as?
@Yatin issue date and time should be based on the actuals (when transaction occurs).
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