Recent amendments to the Rulebook on Value Added Tax and the Rulebook on Electronic Invoicing have also amended and further clarified the provisions relating to the issuance of invoices for supplies charged in foreign currency.
These amendments apply from tax periods beginning on 01 April 2026.
For monthly VAT taxpayers, this means April 2026. For quarterly VAT taxpayers, this means the April–June 2026 quarter.
Namely, following the amendments, the following relevant provisions apply:
Rulebook on VAT – Article 197
If the consideration for the supply of goods or services is collected entirely in foreign currency, the tax base amount and VAT amount, or the amount of consideration for individual supplies of goods or services, shall be stated in foreign currency, while the total tax base amount and total VAT amount, or the total amount of consideration, must be stated in dinars.
If the consideration for the supply of goods or services is collected entirely or partially in dinars, the tax base amount and VAT amount, or the amount of consideration for individual supplies of goods or services, the total tax base amount and total VAT amount, or the total amount of consideration, shall be stated in dinars.
Rulebook on Electronic Invoicing – Article 12, Paragraphs 3 and 4
The information on the unit price of goods or services in the line items of an electronic invoice may be stated with more than two decimal places, while information on all other amounts may be stated with a maximum of two decimal places.
The data referred to in paragraph 3 of this Article shall be stated:
- in dinars, if payment is made entirely or partially in dinars;
- in foreign currency, if payment is made entirely in foreign currency.
If payment is made entirely in foreign currency, the information on the total amount of consideration (for a transaction for which there is no obligation to calculate VAT), tax base, and VAT shall also be stated in dinars.
Therefore, if payment for supplied goods and services is made entirely in foreign currency:
- individual prices of goods and services must be stated in the foreign currency in which payment is made, as well as data relating to individual supplies;
- the total tax base amount, VAT, and total amount payable must mandatorily be stated in dinars.
This rule applies only where payment is made entirely in foreign currency. Different rules apply where payment under the invoice is made partly in dinars and partly in a foreign currency.
We particularly draw attention to these provisions, applicable from tax periods beginning on 01 April 2026, for taxpayers invoicing/paying rent in foreign currency and those receiving invoices from tax representatives of foreign suppliers.
It is necessary to monitor whether unit prices and all other amounts are stated in foreign currency (EUR, USD, etc.) and whether the total tax base, total VAT, and total amount payable are stated in dinars. If these conditions are not met, the electronic invoice is not considered valid, and the taxpayer who received it has their right to input VAT deduction jeopardized.
The regulations do not define how the transitional period will be handled. It remains unclear whether an invoice for a supply performed up to and including 31 March 2026, but issued as an electronic invoice starting from 01 April 2026, should comply with the “old” or the “new” rules, meaning that taxpayers claiming input VAT from such invoices are exposed to tax risk.
For invoices issued from 01 April 2026 for supplies carried out from 01 April 2026, it is undisputed that the new rules apply and that the invoice must comply with them in order for the taxpayer to exercise the right to deduct input VAT.
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