BR-S-10Standard-rated VAT breakdown carries an exemption reason

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-S-10.

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The message ZATCA prints

[BR-S-10]-A VAT breakdown (BG-23) with VAT Category code (BT-118) "Standard rate" shall not have a VAT exemption reason code (BT-121) or VAT exemption reason text (BT-120).

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.

Standard-rated VAT breakdown carries an exemption reason

Reported asexemption_reason_presentan exemption reason where none belongs

What is wrong

A cac:TaxSubtotal directly under the invoice's own cac:TaxTotal is coded S - standard rated - under the VAT tax scheme, and its own cac:TaxCategory carries a cbc:TaxExemptionReason or a cbc:TaxExemptionReasonCode. EN 16931 rule BR-S-10, which ZATCA runs, forbids an exemption reason on a standard-rated breakdown. SDK 3.4.8 flags it as a warning, not a rejection: the finding is reported without failing the document by itself (EN:1533). The test reads the standard-rated breakdown itself, so an exemption reason on an exempt or zero-rated breakdown of the same invoice does not trigger it, and an invoice that mixes standard-rated and exempt supplies can satisfy every rule. That was not so in SDK 3.0.8, which looked for an exemption reason anywhere in the document, so a mixed invoice whose exempt breakdown carried the reason its own rule, BR-E-10, required could not pass both. SDK 3.4.8 fixed the test and removed BR-E-10.

What to check in your ERP

An exemption reason has no place on a standard-rated breakdown. Look for an export template that writes cbc:TaxExemptionReason or cbc:TaxExemptionReasonCode on every breakdown regardless of category, for a reason left on a tax code that was later changed to a taxed one, and for a reason carried over by a document copied from an earlier exempt invoice. Remove it from the standard-rated breakdown only: the exempt and zero-rated breakdowns on the same invoice keep their reason codes.

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

(/*/cac:TaxTotal/cac:TaxSubtotal/cac:TaxCategory/cbc:ID/text() = 'S') and (exists(cbc:TaxExemptionReason) or exists(cbc:TaxExemptionReasonCode))

Reported test

not(cbc:TaxExemptionReason) and not(cbc:TaxExemptionReasonCode)
Evaluated against
/*/cac:TaxTotal/cac:TaxSubtotal/cac:TaxCategory[normalize-space(cbc:ID) = 'S'][cac:TaxScheme/normalize-space(upper-case(cbc:ID))='VAT']
Source
vendor/zatca/schematron/CEN-EN16931-UBL.xsl:1534

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.

Document
bad-108-standard-exemption-reason.xml
Mutabiq's verdict
Passed
Reported as
exemption_reason_presentan exemption reason where none belongs

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Rules evaluated against the same part of the document. One wrong value often reports several of them at once.

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