The requirement will apply to any transaction types within B2G, B2B and B2C sectors. However, the companies sending invoices to public entities behind eSPap will have to do it in the structured format CIUS-PT, not in PDF format. Although PDF invoices are considered electronic for tax purposes, eSPap only accepts structured e-invoices, which PDFs are not.
Furthermore, the same Dispatch 351/2021-XXII officially suspends the ATCUD number on tax-relevant documents until 2023. As we wrote last…