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Subject: Re: [ubl] [Fwd: RE: Review of "UBL Submission from TAX ML technicalcommittee"]
From:
To: Tim McGrath <>
Date: Mon, 20 Jun 2005 15:44:04 -0400
Tim,
Thank you for making available the comments from the Swedish governement on
the TaxXML paper, and thank you to Martin Forsberg and Soren Lennartsson
for taking the time to contribute this very appreciated feedback.
I forwarded these comment to our work group and have summarized the
comments primarily from myself and Dave Watt of HM Revenue and Customs:
1. In his comments, Soren suggests having the model checked by other user
groups such as ODETTE (Organisation for Data Exchange through
Tele-Transmission in Europe - representing European Automotive). We are
certainly in favor of having as many user groups as possible look at the
model to solicit feedback. Dave is a member of the Odette European Invoice
Task Force and could arrange to have the model circulated. Dave has also
been working with the JAI (Joint Automotive Industry) group on their Global
Invoice Project (GIP), which covers the AIAG (Automotive Industry Action
Group) in the USA, Odette in Europe and JAMA/JAPIA (Japanese Auto
Manufacturers Association/Japanese Auto Parts Industry Association) in
Japan and South Korea.
The work group will determine whether the document is ready to be
distributed more broadly.
2. We generally agree with Soren’s observations on the "two schools of
thought" on the (level of) invoice data content - i.e. the insular/stand
alone (document) approach, where all material data content is
self-contained within each message, and the more process-orientated view,
where some of the "tax-critical" data content may be exchanged, up front,
on other documents (e.g. suppliers VAT registration numbers, item prices
etc.), which obviates the need for further repetition within each invoice
message.
However, it should be noted that our initial analysis was deliberately
limited to some of the basic commercial messages involved in the supply
chain. While there may be additional messages that could supply certain
information up front, the analysis of messages we looked at needed to
assume a "worst case" scenario where all of the information required would
need to be supplied. On the other hand, the reference model could be
extended to then draw attention to the fact that derogations may be allowed
by the tax authorities in some countries, that permit the exchange of
certain "static" data, on documents or by means other than in the invoice
message itself. A detailed analysis of these supplementary messages could
be included in a subsequent iteration of the document.
3. Soren comments "the model seems poor in distinguishing between the
information about tax for commercial assessment purposes on the one hand
and tax liability and mandatory reporting of tax on the other." It should
be pointed out that, in the Scope section of the document, it is explained
that (B2G) tax reporting is NOT encompassed in the current model, but will
be included in a future iteration. The work group chose to limit the
initial scope and focus to the commercial messages.
On the other hand, Soren has provided quite a good view as to how VAT
operates in Europe. We would like to include any information that helps to
clarify how indirect taxes operate and will consider the inclusion of this
EU-specific information (as well as other jurisdiction specific detail) in
an appendix to the model, to add clarity for the "non-EU- initiated"
reader.
4. Regarding Soren's comment that "The proposal, listing all commercial
messages as potential indirect tax messages is prone to sub-set
proliferation", again, due to the initial scope and focus of the analysis,
the work involved assessing the commercial messages involved in the supply
chain for their relevance to the determination and ultimate reporting of
Indirect Tax, rather than to look at the total process of Indirect Tax and
determine the messages required. However, we agree that users will be more
helped by a model guiding them to solutions and that there should be clear,
unequivocal guidance as to the point where tax liability is determined.
This, as well, is something that could be accommodated within appendices on
the various indirect taxes.
Thank you again and I look forward to any additional feedback.
Regards,
John Glaubitz
Tim McGrath
<tmcgrath@portcom To:
m.com.au> cc:
Subject: [ubl] [Fwd: RE: Review of "UBL Submission from TAX ML technical committee"]
06/13/2005 10:49
PM
As discussed on the call here are the comments from the Swedish government
on the Tax XML paper.
