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March 9, 2022
2022-0387

New Zealand delays introduction of proposed changes to GST invoicing requirements

New Zealand's 2021 omnibus tax bill introducing comprehensive changes to the existing Goods and Services Tax (GST) invoicing rules was reported back to Parliament on 3 March 2022, following review of submissions. The most significant change is the delayed introduction of the rules from 1 April 2022 to 1 April 2023.

Some businesses will appreciate the extra lead in time for implementation. Others may be disappointed where they were looking to immediately take advantage of the increased flexibility of the proposed new rules.

The delay is based on the determination that a March 2022 introduction would not have provided businesses with sufficient time to understand and implement the new requirements. While providing time to implement law changes generally makes sense, the proposed changes have been drafted in a way that businesses complying with the current tax invoicing requirements would not need to make any changes to comply with the new rules, thereby removing the need for any lead time for business.

Importantly, one change is still going ahead this year. The bill proposes to remove the requirement to obtain Inland Revenue approval to issue buyer-created tax invoices. This will be effective from the date the tax bill receives Royal assent, likely to be on or slightly before 1 April 2022.

The amended bill also seeks to reinstate the simplified tax invoice for supplies not exceeding NZ$1,000 and, to avoid any unintended consequences, to retain the terms "invoice" and "tax invoice" by making it clear that any references to these terms are treated as references to the new terminology. The key proposed changes remain as follows:

  • Replacement of the current requirement to issue and hold tax invoices and credit/debit notes to recipients with a requirement for suppliers to provide GST-registered recipients with information in relation to the supply (taxable supply information) or an amendment to the supply. The form of the communication of this information is not prescribed (i.e., no requirement to issue a document in a prescribed form, as is the case now).
  • Both suppliers and recipients to be required to hold records of taxable supplies in their systems, including specified information in relation to supplies.
  • Input tax deductions to be supported by business records showing the GST that has been borne on the supplies (no need to hold a "tax invoice").
  • Increasing the low-value threshold from NZ$50 to NZ$200, under which taxable supply information is not required to be provided.

Interaction with e-invoicing initiatives

The delay above also does not appear to be consistent with the separate government initiatives concerning the roll out of electronic invoicing (see Home | eInvoicing). The Government is encouraging businesses and government agencies to adopt e-invoicing and, while there are currently no mandates for businesses to move to e-invoicing, all central government agencies have a target in place to be able to receive e-invoices by 31 March 2022. The GST invoicing changes would assist in bringing the GST rules into alignment with the use of e-invoicing.

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Ernst & Young Limited (New Zealand), Auckland

 

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