The SUNAT issued last July Superintendency Resolution No. 123-2022/SUNAT, a regulation that modifies the normative on electronic remittance guides and establishes the obligatory nature of their use, and among its main changes stand out: the elimination of the Guide Invoice, the birth of the Carrier Remittance Guide and the exclusion of the issuance of Electronic Remittance Guides from the Shipping Systems. Electronic Issuance (SEE) through the Electronic Service Operators (OSE); as well as the introduction of the “non-conformity” process of the Referral Guide.
According to Renzo Alcántara, General Manager of TCI, the biggest challenge presented by this new obligation is to educate the main taxpayers in the change process, since they need the necessary support to implement it efficiently while respecting current regulations. “The challenge is presented in the coordination between the parties: seller, dispatch location, buyer, reception location, the carrier and the subcontractors, since it is required to have all the data of the new format at the time of issuing the electronic guide”Add.
The expert also highlights that SUNAT considers it sufficient for the taxpayer to show the issuing QR or RUC together with the series and correlative to support the transfer of merchandise, however, in practice the buyer requires physical proof with a seal and signature from the supplier. to accept your bills and pay them. “Here there is a challenge to manage: while SUNAT does not require a copy of the printed representation, commercially the acquirer does”warns Alcántara.
Demand for advice, time and support:
TCI, based on its experience and knowledge of having developed the software for Electronic Service Operators – OSE, has been contributing to the implementation of this new format with more than 40 companies, providing them with test environments that ensure proper issuance upon exit. to production and thus collaborate with the implementations required by SUNAT. With this, more companies interested in transforming their electronic delivery guide issuance process to digital would be joining, motivated by the mandatory nature of these as of January 1, 2023.
Renzo Alcántara recommends that the new format of electronic remittance guides be validated by the OSEs so that the main taxpayers can count on 24×7 support for their logistics operations and ensure business continuity. “They are concerned about the contingency procedures that require counting for when SUNAT enters maintenance, since the guides have not been processed with the OSEs since 12/1/2022, and they will require immediate support from 10pm to 7am. ”says the specialist.
Recommendations for better implementation:
It is important to ask ourselves the following question, Do I have to issue a GRE for all goods out of my company’s warehouse? It should only be issued when the supplier is responsible for the transfer of the merchandise and must support it. On the other hand, when the buyer sends a third party to do so, the latter must issue the GRE to collect it, which will be used by the carrier to support the collection of the merchandise; however, for this process, it was usual for the provider to physically issue it.
Large companies need greater control of the delivery status of their merchandise, allowing to place some additional detail for cases of transfer and partial receipt of merchandise, a situation that was not contemplated before but is now possible thanks to the “partial non-conformity”, which It is part of the new process regulated by RS 123-2022.
“For example, partial receptions imply partial non-compliance in the SUNAT portal, and this, in turn, requires the issuance of a GRE for return and return of the merchandise. This situation differs from what is customary to do in the same physical guides, where only the signature, the reason and the items to be returned were placed in writing.”, highlights Renzo Alcántara.
Likewise, the TCI expert warns taxpayers to take into account the payment of the deduction on invoices for products subject to SPOT. “Proof of payment of said deduction must be placed in the GRE-R and GRE-T to send the corresponding merchandise. With this, a sequence for the emission of GRE will be generated; something that is not controlled in the world of paper“, Add.
Data of interest:
- As of September 2022, 706,927 companies are electronic issuers and use different systems to process their electronic payment receipts. 78% of them use the SOL Portal (from SUNAT); 18% issue with their own taxpayer system; and 4% rely on the OSE.
- In September 2022, more than 290 million Electronic Payment Vouchers have been issued. Around 203 million are processed by the OSEs, which indicates that the transactional volume processed by the OSEs authorized by SUNAT itself is much higher than the other issuance systems.
