BR-E-06Exempt allowance carries no VAT rate

Mutabiq checks Saudi ZATCA Phase 2 e-invoice XML before you submit it: pre-validation against published ZATCA requirements, not an approval by the authority. This page explains one rule, BR-E-06.

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The message ZATCA prints

[BR-E-06]-In a Document level allowance (BG-20) where the Document level allowance VAT category code (BT-95) is "Exempt from VAT", the Document level allowance VAT rate (BT-96) shall be 0 (zero).

What Mutabiq reports

One entry for each way this rule can be reported.

Reported as
What kind of value was found — empty, not_15_digits and the like — never the value itself.

Exempt allowance carries no VAT rate

Reported asrate_missingthe rate is missing

What is wrong

A cac:AllowanceCharge whose cac:TaxCategory is coded E - exempt - under the VAT tax scheme carries no cbc:Percent element. EN 16931 rule BR-E-06, which ZATCA runs, requires the VAT rate on an exempt allowance (BT-96) to be zero, and it tests that by comparing the element's value against nought. An absent element is an empty sequence and the comparison against it is false, so leaving the rate out fails the rule exactly as a wrong rate would. The expression matches an allowance at any depth, so one written inside an invoice line or inside a price is judged by it too.

What to check in your ERP

Write cac:AllowanceCharge/cac:TaxCategory/cbc:Percent with a value of zero rather than omitting it. The usual cause is an export template that emits the element only when the value is not nought. Fix it at the template, since the same suppression affects the zero-rated allowances as well, and confirm the discount record holds a numeric zero rather than an empty rate field.

Exempt allowance carries a VAT rate that is not zero

Reported asrate_not_zerothe rate is not zero

What is wrong

A cac:AllowanceCharge whose cac:TaxCategory is coded E - exempt - under the VAT tax scheme carries a cbc:Percent that is not zero. EN 16931 rule BR-E-06, which ZATCA runs, requires the rate on an exempt allowance (BT-96) to be zero. The category code and the rate in the same block contradict each other; a discount taxed at a rate belongs in the standard-rated category (S) instead.

What to check in your ERP

Decide which of the two is right before editing either. A discount against an exempt supply is itself exempt and its rate must be nought; a discount against a taxed supply keeps its rate and the category letter is what has to change. The frequent cause is a discount whose category is copied from the line it applies to while its rate comes from a document-level default, so the two are read from different places and drift apart on any invoice that mixes categories.

The clause that runs

Quoted from the validation-rule stylesheet ZATCA publishes, at the file and line named below. The executed guard is what the check runs; the reported test is what it prints when it fails, and the two are not always the same.

Executed guard

not((xs:decimal(cbc:Percent) = 0))

Reported test

(xs:decimal(cbc:Percent) = 0)
Evaluated against
cac:AllowanceCharge[cbc:ChargeIndicator=false()]/cac:TaxCategory[normalize-space(cbc:ID)='E'][cac:TaxScheme/normalize-space(upper-case(cbc:ID))='VAT']
Source
vendor/zatca/schematron/CEN-EN16931-UBL.xsl:1380

As shipped in ZATCA SDK 3.4.8: the copy quoted here is, byte for byte, the file that release ships. The date in the file name is the name ZATCA gives the file; the rules in it are those of SDK 3.4.8.

A worked example

A synthetic document from the measured test corpus that trips this rule, shown where it differs from one that passed. Mutabiq's report names the class of the value, never the value itself.

Where it differs from a document that passed

  • This example
  • A document that passed
  <cbc:PaymentMeansCode>10</cbc:PaymentMeansCode></cac:PaymentMeans>This example: <cac:AllowanceCharge>This example:   <cbc:ChargeIndicator>false</cbc:ChargeIndicator>This example:   <cbc:AllowanceChargeReason>Volume discount</cbc:AllowanceChargeReason>This example:   <cbc:Amount currencyID="SAR">0.00</cbc:Amount>This example:   <cac:TaxCategory>This example:     <cbc:ID schemeID="UN/ECE 5305" schemeAgencyID="6">E</cbc:ID>This example:     <cbc:Percent>15.00</cbc:Percent>This example:     <cac:TaxScheme>This example:       <cbc:ID schemeID="UN/ECE 5153" schemeAgencyID="6">VAT</cbc:ID>This example:     </cac:TaxScheme>This example:   </cac:TaxCategory>This example: </cac:AllowanceCharge><cac:TaxTotal>  <cbc:TaxAmount currencyID="SAR">0.00</cbc:TaxAmount>
Document
bad-59-e-allowance-nonzero-rate.xml
Mutabiq's verdict
Not passed
Reported as
rate_not_zerothe rate is not zero

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