E-invoicing self-evaluation questionnaire

Are you in control and long-term auditable?

If you answer more than 10 questions in the affirmative,
you should consider bolstering your e-invoice evidence.

1. Do you send or receive invoices in more than 3 different file formats?
2. Are more than 50% of your invoicing processes automated?
3. Do you have more than 3 different invoice production chains/ERP systems or entry points/workflow systems?
4. Do your different e-invoicing systems mostly function separately i.e. integration could be significantly improved?
5. Would you qualify your IT systems and business processes as decentralized?
6. Are there significant weaknesses in the way you collect and archive audit trails of all tax-relevant processes in your sphere of responsibility (until the invoice is sent/made available if you are a supplier, and from the moment it is received/accessed if you are a buyer)?
7. Are any communications channels of invoices or invoice data unprotected or protected with a security level below SSL or equivalent?
8. Do you send or received self-billing invoices?
9. Does your process include external invoices as well as intercompany invoices?
10. Does your process include a significant number of customers and/or suppliers?
11. Does your process include trading partners of significantly different sizes?
12. Does your relevant trading partner network change significantly over time?
13. Are your trading partners generally the commercially dominant party between the two of you?
14. Do you rely on external data centre hosting providers?
15. Do you rely on external application management providers?
16. Do you rely on external systems management providers?
17. Do you rely on external providers of technical communications infrastructure e.g. hosted B2B gateways or VANs?
18. Do you use any ASPs?
19. Do you outsource any processes to a BPO provider?
20. Do you use any “cloud” services e.g. for data storage?
21. Do you make use of a shared service centre within a corporation?
22. Do you make use of a centralized purchasing organization within a corporation?
23. Are most invoices standalone rather than being covered by an explicit purchase order?
24. Do you have a medium or high staff turnover in your administrative organization (more than 20% of administrative and relevant IT staff leaves within 5 years?)
25. Have you yet to put in place third party certification based on ISO 27001 or a SAS70 audit?
26. Have you yet to put in place a comprehensive archiving strategy for original versions of key pre- and post-contractual documents and communications?
27. Do you issue or receive invoices under multiple countries’ VAT numbers?
28. Is your legal archive, if any, physically located within a country that has a low level of diplomatic and tax cooperation with the countries you customarilly trade in?
29. Do your invoice process controls (including archiving of audit trails and invoices) take place in multiple countries for one and the same invoice?
30. Are the daily communications of the people/organizations involved in your invoicing control framework in more than three languages?
31. Are the service providers involved in your invoicing processes, if any, located in multiple countries?
32. Are the applicable laws and jurisdiction chosen for contracts with your service providers in multiple countries, many of which have a low level of diplomatic and tax cooperation with the countries you customarilly trade in?
33. Do your invoicing processes involve many different subsidiaries?
34. Do you yet have to put in place a formal contract management system that handles enforceability and evidence of contracts over long periods of time?
35. Do you yet have to formalize agreements within your extended corporation for any IT or processing services provided between internal entities?
36. Does your corporation’s legal setup change relatively frequently (closing down of subsidiries, regional management reorganizations, expansion to new jurisdictions etc)?
37. Have your company or any of its subsidiaries had VAT sanctions such as administrative fines or non-refund of input VAT imposed on them in the past five years?
38. Do you send or receive invoices under the VAT/GST laws of Spain, Portugal, France, Belgium, Netherlands, Denmark, Germany, Latvia, Lithuania, Poland, Czech Republic, Slovenia, Slovak Republic, Austria, Switzerland, Greece, Italy, Hungary, Romania, Bulgaria, South Africa, Argentina, Mexico, Brazil, Chile, South Korea, Taiwan, Japan, Russia, China, India, Pakistan?
39. Do you expect your trading partners to answer “yes” to more than 10 of the above questions?