Actual tax points: VAT invoices: self-billing
Under an approved self-billing arrangement it is the customer who prepares the VAT invoice. For most other VAT purposes the self-billed invoice serves the same purpose and has the same effect as a VAT invoice issued by the supplier. But for time of supply purposes not all self-billed VAT invoices create a tax point.
Time of supply law refers consistently to an invoice that has been issued by the supplier or in similar terms. Therefore, as a general principle, a tax point is not created where, for example, the invoice is issued by the customer, as in the case of a self-billing arrangement.
The exception to this is a self-billed invoice that falls within the scope of the 14 day rule (in other words those covered by section 6(5) of the VAT Act 1994 – see VATTOS2230). This is specifically provided for in paragraph 2B(4) of Schedule 11 VATA 1994 (see VATTOS2295). As a result, a self-billed invoice issued within 14 days of the basic tax point has the same potential to create the tax point for the supply as it would if it had been issued by the supplier.
Paragraph 2B(4) also allows the issuer of self-billed invoices to elect not to follow the 14 day rule or to apply for an extension under section 6(6) (see VATTOS2235).In either case the issuer (ie the customer) must inform the supplier of what has been done on their behalf.
In all other circumstances, for example where a self-billed invoice is issued in advance of the basic tax point or it is in respect of a supply covered by one of the time of supply regulations, a tax point is not created. This is put beyond doubt by paragraph 2B(3) of Schedule 11 (see VATTOS2295) and regulation 13(3F) of the VAT Regulations 1995 (see VATTOS2310) respectively.