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E-Fatura ve E- Defter Hk.

E-Fatura ve E- Defter Hk.

ÖZET

Yasal düzenlemeler ışığında kapsama giren mükellefler ve e fatura hakkında bilinmesi gerekenler

 Giriş

T.C. Maliye Bakanlığı vergi kanunlarında kendisine verilmiş olan yetkiyi kullanarak 421 Seri Nolu Vergi Usul Kanunu Genel Tebliğinde e-fatura ve e-defter uygulamasının uygulama alanını genişletmiştir. Bu sirkülerimizde mükelleflerin bu genişleme alanı içinde olup olmadıklarını tespit etmelerine olanak sağlamak ve sonrasında yapmaları gereken işlemleri anlatmaya çalıştık.

 

Kapsamı

58. sıra No.lu Vergi Usul Kanunu Sirkülerinde; 421 Sıra Numaralı Vergi Usul Kanunu Genel Tebliği İle elektronik defter tutma ve elektronik fatura uygulamasına dahil olma zorunluluğu getirilen mükelleflerin durumları hakkında açıklamalara yer verilmiştir. Buna göre;

  • 5015 sayılı Petrol Piyasası Kanunu Kapsamında madeni yağ lisansına sahip olanlar,
  • 5015 sayılı Petrol Piyasası Kanunu kapsamında madeni yağ lisansına sahip olanlardan 2011 takvim yılında mal alan mükelleflerden 31 / 12 / 2011 tarihi itibariyle asgari 25 milyon TL brüt satış hasılatına sahip olanlar,
  • 4760 sayılı Özel Tüketim Vergisi Kanununa ekli(III) sayılı listedeki malları imal, inşa veya ithal edenler,
  • 4760 sayılı Özel Tüketim Vergisi Kanununa ekli (III) sayılı listedeki malları imal, inşa veya ithal edenlerden 2011 takvim yılında mal alan mükelleflerden 31/12/2011 tarihi itibariyle asgari 10 milyon TL brüt satış hasılatına sahip olanlar

( a ) ve ( c ) bentleri kapsamına giren mükellefler kuşkusuz e-fatura ve e-defter uygulamasına tabi olmuşlardır. Uygulamada duraksamaya neden olan düzenleme ( b )  ve ( d ) bentleri kapsamıdır. Buradan hareketle;

  • 2011 yılı gelir tablolarında brüt satış hasılatı rakamı 25 milyon ve üzerinde olanların durumu;

Madeni yağ lisansına sahip olanlarda her ne türde olursa olsun 2011 yılında herhangi bir mal alış yapanlar 25 milyon TL üzerinde ciroya sahipler ise e-fatura ve e-defter uygulaması kapsamına giriyorlar.  Yıllık satış hasılatı 25 milyon üzerinde olan ve 5015 sayılı Petrol Piyasası Kanununa göre madeni yağ lisansı sahibi mükelleflerden mal almayan bir mükellef olamayacağını listenin tetkikinden kolayca anlaşılabilmektedir. (Liste için tıklayınız)

Listede yer alan mükellefler arasında yaygın perakende akaryakıt satışı yapan firmaların olması şu genellemeyi yapmamıza imkan vermektedir. 2011 yılı brüt satış hasılatı 25 milyon üzerinde olan ve en az bir motorlu taşıtı olan mükellef e-fatura ve e-defter uygulamasına geçmek zorundadır.

  • 2011 yılı gelir tablolarında brüt satış hasılatı rakamı 10 milyon ile 25 Milyon arasında  olanların durumu;

4760 sayılı ÖTV Kanununa ekli (III) sayılı listedeki malları ithal, imal ve inşaa edenler tabiri mükellefleri yanılgıya itmektedir. Bu listenin incelenmesinde birçok zincir marketlerin listede yer aldığı göze çarpmaktadır. Yasal düzenlemeye göre bu listede yer alan mükelleflerden mal alımı yapıp cirosu 10 milyon ile 25 milyon arasında olanlar da e-fatura ve e-defter uygulamasına tabi olacaktır. ( Liste için tıklayınız ) Mal alımından kasıt sadece ticareti yapılan mal değil işletme malzemesi veya mutfak malzemesi olarak da alınan perakende ürünlerde yasal düzenlemeye göre kapsam içine girmektedir. Alım yapan mükellefin faaliyet konusunun uygulama ile ilişkisi yoktur.

Her iki durumda da ortak olan hususlar ise şöyledir;

Bu mükelleflerde hizmet alan mükellefler sınırların içinde olsalar dahi zorunlulukları bulunmamaktadır. Örneğin; (III) sayılı listede yer alan bir mükelleften konaklama veya restaurant hizmeti alan bir mükellef bu kapsama dahil olmayacaktır, yada madeni yağ lisans sahibi olan bir mükelleften danışmanlık hizmeti satın alan bir mükellef sadece bu alışverişten dolayı kapsama girmemektedir.

 

  • 2011 yılı gelir tablolarında brüt satış hasılat rakamı 10 milyon altında olanların durumu;

Bu mükelleflerin henüz bir şey yapmalarına gerek yoktur. Ancak ihtiyari olarak sisteme dahil olma isteği var ise kapsam içinde olan mükelleflerden istenen belge ve bilgileri temin etmek suretiyle sisteme entegre olabilirler.

 

E-Fatura Nedir  ve Sayladığı Faydalar Nelerdir? 

E-fatura, faturalamanın kağıtsız olarak elektronik yollarla yapılmasıdır. Çoğunlukla fatura kişi veya kurumlardan yine kişi veya kurumlara e-posta yoluyla gönderilir. Faturayı hem düzenleyen hem de alan taraf için ödeme kolaylığı başta olmak üzere çok sayıda avantaj sağlar. Arşivlemede kolaylık sağlayan ve kağıt israfını oldukça düşüren e-fatura, tüm dünyada çok sayıda ülke tarafından hayata geçirilmiş veya geçirilmek için çalışılmaktadır.

 

Geçiş Süresi 

E- fatura için zorunluluk kapsamına giren mükellefler en geç 01 / 09 / 2013 tarihine kadar başvurup, 01/01/2014 tarihi itibariyle sisteme geçmeleri gerekmektedir. E-Defter için ise 01/09/2014 tarihine kadar başvuruda bulunup 2014 takvim yılı itibariyle sisteme geçmeleri gerekmektedir. Öncelikli olarak 2011 yılı brüt satış hasılatı sınırları üzerinde ise yukarıda linklerini vermiş olduğumuz listelerde bulunan mükelleflerden mal satın alıp almadığınızı kontrol ediniz. Şahsi görüşümüz ciro sınırını aşmış iseniz muhakkak uygulamaya zorunlu olarak geçmek zorundasınızdır. E- Faturanın en ağır yaptırımı, kapsam içinde olması gerekirken kapsam dahiline girmeyen mükelleflerin bu faturaları hiç düzenlenmemiş hükmünde sayılacağından yaptırımları çok ağır olabilir.

Kullanım Yöntemleri

  • Gelir İdaresi Başkanlığı E-Fatura Portal Yöntemi

Portal Yöntemi Gelir İdaresi Başkanlığı tarafından www.efatura.gov.tr internet adresinden ücretsiz olarak sunulan bir e-fatura uygulaması hizmetidir. Bu yöntem ile faturalarınızı GİB Portal üzerinden manuel olarak oluşturabilir veya kendi bilgi işlem sisteminizde Başkanlığın belirlediği formatta oluşturup Portal hesabınıza yükleyebilirsiniz.

  • Özel Entegrasyon Yöntemi

Başkanlık’tan özel entegrasyon izni almış mükelleflerin bilgi işlem sistemleri kullanarak da e-fatura uygulamasından yararlanabilirsiniz. Bu durumda mali mührünü ürettiren mükellefler, Başkanlık’tan özel entegrasyon izni almış kurumlara başvuru yaparak uygulamaya dahil olabilirler. Özel entegrasyon izni için başvuran mükelleflerin testleri devam etmekte olup, testlerini başarı ile tamamlayarak Başkanlık’tan özel entegrasyon izni alan kurumlar www.efatura.gov.tr internet adresinden yayınlanmaya başlanmıştır.

  • Bilgi İşlem Sisteminin Entegrasyonu Yöntemi

Bu yöntem, kendilerine ait bilgi işlem sistemini Başkanlığın sistemine entegre ederek 7/24 kesintisiz bağlantı sağlayabilecek mükelleflerin kullanabilmeleri amacıyla geliştirilmiştir. Bu yönteme başvuran mükellefler başvuru dilekçelerinde e-Fatura uygulamasından entegrasyon yöntemi ile faydalanmak istediklerini belirmek zorundadırlar. Mükellefler isterler ise başvuru dilekçesinde belirtmek şartıyla, entegrasyon çalışmaları tamamlanana kadar Portal hesaplarının kapatılması talep edebilirler. Bu süre hiçbir hal ve koşulda 421 Sıra Nolu Vergi Usul Kanunu Genel Tebliği’nde belirtilen 31.12.2013 tarihini geçemez. Bu tarihe kadar entegrasyonunu tamamlayamayan mükellefler faturalarını GİB Portal üzerinden düzenlemek zorundadırlar.

 

Sorumluluklar ve Cezai Yaptırımlar

  • Bilgi işlem sistemlerinin entegrasyonu yöntemiyle elektronik fatura uygulamasından yararlanan mükellefler, sistemlerini kesintisiz 7 gün 24 saat fatura ve ilgili mesajları alabilir ve gönderebilir halde açık tutmak zorundadırlar. Mücbir sebepler dışında bu zorunluluğa uymayan mükelleflerin entegrasyon izinleri iptal edilecek olup, elektronik fatura uygulamasını sadece portal yöntemiyle kullanabileceklerdir,
  • Bilgi işlem sistemlerinin entegrasyonu yöntemiyle elektronik fatura uygulamasından yararlanan mükellefler, sistemleri üzerinde yapacakları bakım, onarım, gözden geçirme vb. işlemler nedeniyle sistemlerine erişim kesintiye uğrayacak ise bu kesintiden önceki üç işgünü içerisinde hangi tarihte ve ne kadar süreyle sistemlerinin kesintiye uğrayacağını Gelir İdaresi Başkanlığı’na bildirmekle yükümlüdürler. Kesinti süresi hiçbir surette iki günü aşamaz.
  • Elektronik fatura ve elektronik deftere ilişkin olarak bu Tebliğ ile getirilen zorunluluklara uymayanlar hakkında, Vergi Usul Kanununun ceza hükümleri tatbik olunur.
  • Elektronik fatura uygulamasına dâhil olma zorunluluğu getirilen mükellefler elektronik fatura uygulamasına kayıtlı olan diğer mükelleflere kâğıt ortamında fatura düzenleyemezler; düzenlemeleri halinde kâğıt ortamında düzenlenen bu faturalar hiç düzenlenmemiş sayılır.
  • Elektronik fatura uygulamasına dâhil olma zorunluluğu getirilen mükelleflerin elektronik fatura uygulamasına kayıtlı olan diğer mükellefler tarafından gönderilen elektronik faturaları almaları zorunludur. Bu zorunluluğa uymayan mükellefler hakkında Vergi Usul Kanununun ilgili hükümlerinde belirtilen fatura almayan mükelleflere tatbik olunan cezai hükümlerin uygulanacağı tabiidir.
  • Bu Tebliğ ile elektronik defter tutma zorunluluğu getirilen mükellefler kâğıt ortamında defter tutamazlar. Bu mükellefler kâğıt ortamında defter tutmaları halinde hiç defter tutmamış sayılırlar.

Başvuru Yöntemleri ve Formlar

E-Fatura uygulamasından zorunlu veya ihtiyari olarak yararlanmak isteyen mükellefler, elektronik mali mühür sertifika sahibi taahhütnamesini doldurup belgeler ekine  Şirket kuruluş sözleşmesi Ticaret Sicil Gazetesinde 1/10/2003 tarihinden önce yayımlanmış ise ilgili ticaret sicil gazetesinin noter onaylı örneği veya aslının getirilmesi halinde Başkanlıkça onaylanmak üzere fotokopisi, (Sonradan unvan değişikliği yapılması halinde en son unvanın ilan edildiği ticaret sicil gazetesinin noter onaylı örneği veya aslının getirilmesi halinde Başkanlıkça onaylanmak üzere fotokopisi.) Başvuru formuna şirket adına imza atan kişi veya kişilerin yetkili olduğunu gösteren şirket imza sirkülerinin noter onaylı örneği eklenmelidir.

 Başkanlık tarafından yapılan değerlendirme sonrasında başvuruları uygun bulunan gerçek kişi mükelleflerin kullanıcı hesapları Başkanlıkça tanımlanarak aktive edilir. Başvurusu uygun bulunan tüzel kişilere, Kullanıcı hesaplarının tanımlandığı ve uygulama bünyesinde kullanmak zorunda oldukları Mali Mühür sertifikalarını TÜBİTAK-UEKAE Kamu Sertifikasyon Merkezinden temini işlemlerine başlayabilecekleri bilgisi verilir. Bedeli KAMU SM hesabına yatırılan sertifikalar KAMU SM tarafından başvuru sahibi tüzel kişilere teslim edilir. Başkanlık tarafından yapılan değerlendirme sonrasında başvuruları uygun bulunan tüzel kişi mükelleflerden Mali Mühürlerinin temini işlemlerini yerine getirenlerin kullanıcı hesapları Başkanlıkça tanımlanarak aktive edilir. Hesaplarının aktif hale gelmesi birlikte kullanıcılar, herhangi başka bir işlem yapmalarına gerek kalmaksızın e-Fatura Portalı aracılığı ile uygulamada tanımlı diğer kullanıcılara e-fatura göndermeye ve bunlardan e-fatura almaya başlayabilirler.

e-Fatura Uygulamasına bilgi işlem sistemlerini entegre etmek isteyenlerin entegrasyon başvurusunda bulunmaları gerekmektedir. Entegrasyon başvurusu kullanıcı hesabı oluşturmak için yapılan başvuru ile birlikte yapılabileceği gibi kullanıcı hesabı oluşturulduktan sonra da yapılabilir.

Sonuç

E-Fatura ve E-Defter uygulaması, Gelir idaresinin ücretsiz olarak kullandırdığı program vasıtası ile, kendi yazılımınızın sisteme entegre edilmesi modeli ile veya aracı kuruluşlar vasıtası ile kullanabileceğiniz belge alış veriş platformudur. E- defter ise e- fatura ile birlikte kağıt ortamında bir kayıt sisteminin olmadığı kayıtların, teftiş ve incelemenin de dijital ortamda yapıldığı bir sistemdir. Bu çalışmanın sizlere faydalı olacağını ümit eder, konu ve süreç hakkındaki daha detaylı bilgi ve değerlendirmeler için bizimle irtibata geçmenizi rica eder, çalışmalarınızda başarılar dileriz.

 

Saygılarımızla,

 

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