インボイス制度の仕組みと実務 — 適格請求書発行事業者

The Invoice System (formal name: Qualified Invoice Preservation Method) is a new consumption-tax system that started on October 1, 2023. To receive a consumption-tax input-tax credit, in principle one must now retain qualified invoices (Article 30, Consumption Tax Law).

The background is the existence of the reduced tax rate introduced in October 2019 (8% for food/beverages and newspapers, 10% for other items). With multiple tax rates coexisting, a system explicitly stating the precise rate and tax amount on invoices became necessary in order to achieve accurate consumption-tax calculation and proper input-tax credit.

Consumption tax is an indirect tax borne by final consumers and remitted to the state by businesses. Each business pays tax by deducting consumption tax on purchases (paid) from consumption tax on sales (collected). This is "input-tax credit."

After the Invoice System started, retaining a "qualified invoice" is generally required to receive this credit. Conversely, purchases from counterparties who cannot issue invoices (such as tax-exempt businesses) are in principle not creditable (subject to the transitional measure described below).

To issue qualified invoices, you must submit a "Qualified Invoice Issuer Registration Application" to the tax office having jurisdiction over your tax location and obtain registration. Once registered, the National Tax Agency notifies you of your registration number.

A qualified invoice must include the six items specified in Article 57-4 of the Consumption Tax Law. If even one is missing, it is not recognized as a "qualified invoice" and the receiving party cannot receive input-tax credit.

Consumption-tax rounding is an especially important practical issue under the Invoice System. The rule is: rounding must be performed "once per tax rate per qualified invoice."

Industries that sell to large numbers of unspecified persons (retail, restaurants, taxis, parking, etc.) are permitted to issue simplified invoices (such as receipts). On a qualified simplified invoice, specification of the recipient's name can be omitted, and either the consumption-tax amount per rate or the applicable tax rate alone is sufficient.

A business with base-period (two periods prior) taxable revenue of 10 million yen or less is a "tax-exempt business" exempted from the consumption-tax remittance obligation. Tax-exempt businesses cannot issue qualified invoices; therefore, after the Invoice System's start, the problem arises that taxable counterparties cannot receive input-tax credit.

Because suddenly disallowing credit for transactions with tax-exempt businesses would have a large impact, a 6-year transitional measure was established. A certain percentage of credit is permitted even for purchases from non-issuer businesses such as tax-exempt businesses.

When a tax-exempt business registers as an invoice issuer, to lessen the consumption-tax remittance burden, the "20% special exception" was established, capping the remitted amount at 20% of sales consumption tax (i.e., crediting 80% of received consumption tax). It applies to each taxable period including the period Oct 1, 2023 to Sep 30, 2026.

Buyer-side businesses must distinguish whether received invoices are qualified invoices, and qualified invoices must in principle be preserved for 7 years (Article 30, Paragraph 7). Whether the counterparty's registration number is valid can be verified as needed on the National Tax Agency's disclosure site.

Qualified invoices may be delivered electronically (not only on paper). Because electronic invoices correspond to electronic transaction data under the Electronic Books Preservation Act, electronic preservation is mandatory. Japan has adopted the international standard Peppol (Pan-European Public Procurement Online) as the standard specification for electronic invoices, with the Digital Agency operating as the Peppol Authority.