🧾 Can You Change an Issued Invoice to Zero-Rated for a Sample?

 

ZATCA-Compliant Guide (2025)

📌 Scenario:

Your business issued a standard-rated invoice (e.g., SAR 600 / approx. $160) for a product. Later, it was decided that the item should have been issued as a zero-rated sample (i.e., free of charge and not subject to VAT).

❌ Can You Modify the Original Invoice?

No. According to the Zakat, Tax and Customs Authority (ZATCA), once a tax invoice is issued and reported through the FATOORA e-invoicing platform, it cannot be altered or deleted.

✅ What Is the Correct ZATCA-Compliant Solution?

1. Issue a Credit Note

• Reverses the original invoice (SAR 600).
• Must include the UUID of the original invoice.
• State the reason: “Reclassified as zero-rated sample.”
• Submit through your ZATCA-integrated e-invoicing system.

2. Issue a New Zero-Rated Invoice

• Set VAT to 0%.
• Clearly label the item as a “Sample – not for resale.”
• Optionally reference the original invoice for audit trail.

📜 Legal Basis

• Article 53 of the VAT Implementing Regulations: Credit and debit notes must be issued to correct previously issued tax invoices.
• Article 40: Zero-rating applies to specific supplies, including samples not intended for resale, provided they meet the conditions.
• All actions must comply with ZATCA’s anti-tampering and audit trail rules.

🛡️ Why This Matters

• Prevents non-compliance penalties.
• Maintains a clear audit trail.
• Ensures alignment with ZATCA’s real-time reporting requirements.

✅ Best Practices

• Confirm the nature of the supply before issuing an invoice.
• Train your finance team on ZATCA’s credit/debit note procedures.
• Use a ZATCA-approved e-invoicing solution to automate compliance.

Can You Change an Issued Invoice to Zero?

First, it's important to confirm whether your system is integrated with the ZATCA portal. As per Phase 2 of the e-invoicing regulations in Saudi Arabia, all VAT-registered businesses must integrate their ERP or POS systems with ZATCA’s Fatoora platform. This integration ensures that invoices are validated, cryptographically stamped, and returned with a QR code in XML format.

Secondly, once an invoice is issued and cleared through ZATCA, it must be reported in the VAT return for the relevant period. Even if the invoice is zero-rated (such as in the case of exports), it still needs to be submitted and accounted for in the VAT return.

Thirdly, if the invoice in question is an export invoice, you must ensure that you have the necessary supporting documentation. This includes:

• Bayan – the customs declaration document
• Bill of Lading (BL) – for sea shipments
• Air Waybill (AWB) – for air shipments

These documents are critical for proving that the goods were exported and for justifying the zero-rating of VAT on the invoice. Without them, ZATCA may disallow the zero-rating during an audit.

In summary, changing an issued invoice to zero is not a simple edit—it involves compliance with ZATCA’s integration, submission, and documentation requirements. Always consult your tax advisor or compliance officer before making such changes.