2765888 - Brexit: Guidelines for taxes in Sales relevant for SAP S/4HANA Cloud

Please note that the situation has now changed:
The UK is leaving the EU according to the Withdrawal Agreement on January 31, 2020.
At an early stage in the withdrawal process negotiations, the United Kingdom (UK) and the European Union (EU) addressed the unique situation of Northern Ireland and the Republic of Ireland through a special solution. The solution is the Northern Ireland Protocol (NIP) which regulates the special position of Northern Ireland regarding the withdrawal from the EU.

Please see SAP note 2997524. In this SAP note you find changes affecting the supply of goods from and to Northern Ireland was made.

All information listed below affects the supply of goods as well as services between the EU and GB (England, Scotland, and Wales).
This note is valid for SAP S/4HANA Cloud systems.

For general information on this topic, see central SAP Notes 2999933.

SAP S/4HANA Cloud

The UK is leaving the EU according to the Withdrawal Agreement on January 31, 2020.
The Withdrawal Agreement provides for a transition period until December 31, 2020, during which there are no changes for Taxes in Sales from a customs perspective.

Please check for regular updates of this note.

The supply of goods as well as services between the EU and GB (England, Scotland, and Wales) will be treated as taxable cross-border transactions when the BREXIT transition phase has ended, as well as any transactions between the EU and any other non-EU third country.

The correct setup of configuration and master data is a precondition for the correct determination of taxes in sales, including sales billing.

Before initiating new sales processing after the BREXIT transition phase has ended, pay special attention to the following recommendations:

• Please use a tax rate and a tax code provided by FI that represents a non-European Union (EU) business scenario.
  
  The supply of goods between the EU and GB (England, Scotland, and Wales) isn`t treated as intra-community supply when the BREXIT transition phase has ended, and will be taxable. Affected business processes will be identified without a VAT registration number.
  
  
• Please check the output forms and EDI formats of billing documents.
  Besides the VAT registration number of the business process, the VAT registration number of the supplier is also included in output forms and EDI formats.
  
  Please perform the required changes, if there are any.
  Please also adapt legal texts for "Intra-Community Supply (§4 Nr. 1b UStG)" and "Intra-Community Triangulation (§ 25b UstG.)".
  
  

Sales businesses that were initiated before the BREXIT transition phase and are still open after the BREXIT transition phase has ended, must be checked and manually converted.
This is required because, there could be sales documents with unrequested tax results.

• Ideally there aren´t any open sales business processes before the end of the BREXIT transition phase.
  This can be achieved by closing all sales documents before the end of the BREXIT transition phase, for example, by setting a reason for rejection or performing invoicing.
  
  
• Please check the pricing type in the configuration item Copying Control for Billing Documents on item level.
  Key users can access this configuration item in the Manage Your Solution app.
  A redetermination of tax conditions should be performed by, for example, maintaining pricing type 'G' (Copy price elements unchanged and redetermine taxes).
  But please note:
  The creation of subsequent documents for a (referenced) billing document, such as a credit memo request, debit memo request, credit memo or debit memo, and documents for customer returns scenarios, represents an exception to the above. For these processes, the pricing type in copying control on item level should be 'D' (Copy price elements unchanged). When billing documents are canceled, there must be no redetermination.
  
  
• Please check if sales documents include manual changes of tax-relevant data.
  An example of this type of manual change is the setting 'Indicator Triangular Deal Within the EU'.
  A triangular deal in the EU is only allowed if the business partners are EU members.
  When GB (England, Scotland, and Wales) is involved in the business scenario, the flag of this indicator must be manually deleted in the sales documents.
  Otherwise billing documents are created and posted with incorrect sales tax data. To avoid it please look at the last item 'OPTIONAL' of this note.
  
  
• Please consider the date of services rendered for the creation of billing documents.
  The date of services rendered is the date that is relevant for tax determination, meaning that SD tax condition records are determined for the date of services rendered and NOT for the pricing date.
  For sales documents, the date of services rendered is determined as follows:
  If the sales document´s date of service rendered is initial, then the requested delivery date is used as the relevant date, unless the requested delivery date is earlier than the document date. In the latter case, the document date is used as the relevant date.
  For billing documents, the date of services rendered is determined as follows:
  When delivery-related billing is performed and a goods issue date exists, the goods issue date is used as the billing document's date of services rendered. If no goods issue date exists, the billing date is used instead.
  Please be aware that a date of services rendered can be manually entered into the default data on the selection screen. In this case, the manual entry takes priority.
  
  
• Please split long term contract agreements by completing existing ones as of 'Brexit date' and creating new ones that begin as of the 'Brexit date'.
  
  
• Please schedule billing document creation to run monthly to avoid a time difference between the services rendered date and billing date.
  
  
• OPTIONAL:
  The following part provides instruction for how you can make a custom implementation to interrupt the billing of single documents and create a log entry in case incorrect sales tax data is determined.
  
  
• Create a new data transfer routine with a check of data cosistency by implementing custom logic in the cloud BAdI Custom Data Transfer for Billing Documents (SD_BIL_DATA_TRANSFER). Key users can do this in the Custom Fields and Logic app under Custom Logic.
  
  
• The attachment of this note contains a sample source code for this cloud BAdI.
  The check consists of three main steps:
  1. Check whether country GB  is involved in the sales business (that is, whether one of the partners is located in GB or whether the tax departure country is GB).    
  2. Check if the plant is in GB Mainland (England or Scotland or Wales), the date of service rendered is after the BREXIT transition phase and if it isn't a supply of goods.
  3. Check if the Business process is still flagged as EU triangular deal.

• Please don’t forget to implement your own error messages such as 'Indicator Triangular Deal Within the EU is set BUT not allowed if GB with plant in GB Mainland is involved'.
  
  
• Define a new routine number and map it to the BAdI implementation by using the BAdI filter value as the enhancement ID.
  
  
• Assign the correct routine number in the appropriate configuration steps within the configuration item Copying Control for Billing Documents.

        For more information about implementing the cloud BAdI and setting up related configuration, see the cloud BAdI documentation in the Custom Fields and Logic app.

        Check the error log after you have executed one of the apps for billing document creation and look at the error texts shown in the log file.
        Please have a look to the relevant configuration, the business master data, and the setting in the related sales document, mainly indicator 'Triangular Deal Within the EU'.
        Some changes, such as deleting the flag of this indicator, will need to be made manually.

Please note that this document provides only general guidance but cannot replace a consultation with your tax consultant. The document does not cover country-specific legal deviations and tax rules.

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