Invoice discount, how to correct errors?

If the company makes a mistake filling out the invoice and customers cannot opt for the invoice discount, what solutions are possible?

With the 581/2022 response, the Agency replied that everything depends on the date of the work and on the date on which the expenses are incurred.

The owners of a single-family building have carried out energy efficiency interventions that can be facilitated with the Superbonus. The works were entrusted to a company with which the discount on the invoice was agreed

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At the end of 2021, the company issued an invoice, as a down payment, after having carried out part of the work. The invoice was issued with an amount equal to zero as a result of the application of the discount on the invoice

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In April 2022, when the compliance visa was prepared, the professional in charge noted the lack of certification on technical requirements and the appropriateness of expenses. As a result, the professional could not issue the compliance visa.

After a comparison between the parties, it emerged that the technician, given the regulatory uncertainty, preferred to issue the certification at the end of the work. The works were completed in June 2022 and on 24 June 2022 the technician provided the certifications. The company made a mistake in issuing the invoice at the end of December 2021, indicating the application of the discount on the invoice, since, on that date, there were not yet the conditions to be able to exercise the option

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The owners then asked how to remedy the failure to send the communication by April 29, 2022 and if it is possible, for the company, to issue a reversal credit note or a diminishing change note and, subsequently, a new corrected invoice.

The Agency recalled that, in order to opt for the discount on the invoice or for the transfer of credit, it is necessary to obtain a compliance visa, which certifies the conditions that give the right to the deduction, and the certification of the appropriateness of the expenses.

The options must be notified to the Agency by March 16 of the year following the year in which the expenses giving the right to the deduction were incurred (a deadline that for 2022 has been postponed to April 29).

The option of the discount on the invoice must appear expressly in the invoice, issued by the company.

If the indicated deadlines and methods are not respected, the option is ineffective.

The Agency added that, even in the absence of an indication of the discount on the invoice, the invoice issued in December 2021 is fiscally valid and there are therefore no conditions for issuing a reversal of credit or a note of diminishing change (a solution proposed by the owners).

The Agency explained that the company can integrate the invoice with a non-tax document, but only to document the non-payment through the discount and detect the amount to be paid.

The owners can then pay the consideration agreed in the year 2022 and take advantage of the deduction or, alternatively, opt for the transfer of the credit to the company or to third parties within the term of the benefit (which for single-family homes with good jobs has been extended to 31 March 2023).

The Agency concludes with a clarification: the 2021 invoice refers to both driving and towed work. The cost of the towed works will be incurred after the closing of the driving works, which took place

in June 2022.

According to current legislation, the Agency recalled, in order to obtain the Superbonus, the expenses for towed interventions must be incurred in the time interval between the start and the end of the work for the driving interventions.

Consequently, owners can obtain the Superbonus, and possibly opt for the transfer of credit, only for driving work, while for towed work they will be able to access minor building bonuses.

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