Chile November 1 E-Invoicing Mandate - Key Check List

The Chile SII officially published the electronic invoicing mandate in the Official Gazette, mandatory use of the Electronic Tax Document (DTE). The rollout will take place over 3 years and will be based on revenue tiers.

The first deadline is November 1, 2014 for companies billing more than 100,000 UF (approximately 4.2 Million US Dollars).

As you look at solutions, here is a quick check list to ensure your vendor is solving the entire problem and not just pieces. Remember, whatever your vendor doesn’t do you will do. And not just once, but every time the legislation or your SAP ERP system changes.

Key Topics:

• Your vendor should assist you with Folio management as you will need to understand how to apply and reapply for the DTE folio sets.
• Folio management inside the ERP system.  Standard ERP Folio management was built for the paper process. You need to have extensions that manage the electronic call off process and the contingency process that happen in real-time, not just batch.
• You should be able to support all of the outbound DTE documents (many companies overlook the shipping document – the Guia Despacho)
• You must be able to prove your ability to archive the XML
• Support the ability to handle contingency – the process to ensure you can file when the internet is down or slow
• Receive the inbound XML documents (and respond with accept or reject within 8 days) to the government. Many companies overlook the inbound process and the fact that the legal documents come through the government site.
• Produce and manage all of the Libros reporting. As the reports are an aggregate of the transactional data, you do not want a separate tool for Libros and DTE and most importantly from a governance perspective they should read off the ERP tables, not a 3rd party box. For US companies, if you leave the information in a secondary server and not your ERP – you open yourself up to FCPA (Foreign Corrupt Practices Act) issues from the US government. Make sure that if you spent the money on an RP system in Chile, that it is your system of record. Isn’t that why we install common accounting systems. I will always be amazed at the fact that this is overlooked during an evaluation.
• Reconcile Libros at month end to match DTE sent daily
• Most importantly, for a multinational – assist as you register for the certification process. There are two ways to certify your processes in Chile.
  • The first is to certify using a vendor’s platform. Well this is good for small companies, it is not recommended for multinationals for the following reason:
    • You will always reference the RUT Sender, RUT Receiver and RUT Envia in the header information of every document. If you rely on the 3rd party – you will always have the RUT Envia of the provider, not you the company.  This means that a 3rd party is involved in potential audits, the vendor RUT information is on all of your documents, you use their platform and not your ERP platform as the system of record, and if you ever wanted to leave them you are not certified.
    • Additionally, you are going to have to certify your data as part of the process. As long as you have to do it, you should.  It makes sense from a risk perspective and gives you longer term benefit. You want your ERP process certified after you go through all of this.

You will run into a lot of vendors in Chile, and many will say they can support compliance. So ensure you understand the entire process or you will find yourself with operational issues, IT support issues and at risk for audit penalties.  Remember this is as much an ERP issues as it is an integration issue.