e-Tax Invoice investment exemption self-check (editable workbook)

01What is exempt is income, not tax

The clause grants exemption from corporate income tax on income "equal to the expenditure", in an amount of one hundred per cent of what was actually paid. What it exempts is the income, not the tax payable. Read as "one hundred per cent of the tax", a client's figure comes out at twice the benefit.

The value lies in the stacking: the expenditure itself is still relieved the ordinary way — ordinary deduction for expenses, depreciation under section 65 bis (2) of the Revenue Code for assets — and this decree gives a further slice of exempt income on top. The two together are what the measure is worth.

When that hundred per cent is claimed, in which accounting period, against what documents, and whether assets are claimed at once or spread — the decree does not say. Articles 4, 5 and 7 all end on the same sentence: in accordance with the rules, procedures and conditions prescribed by the Director-General. So the qualifying amounts can be aggregated now, but the timing of the claim is an amber cell, to be checked against the notification in force before filing.

02Three heads of spending, because they do not reach the same people

The decree splits the spending three ways, and the persons each reaches are not the same — this is where aggregation most often goes wrong.

• Article 4 — the e-document side. Investment in electronic data preparation systems and electronic data receiving systems, or purchase of computer programs, electronic certificate storage devices, computers and equipment used with them, for preparing, sending, receiving or keeping e-Tax Invoices or e-Receipts. Its second paragraph carves out two kinds of business: providers of e-document preparation or transmission services themselves, and developers writing software to sell or supply to others.
• Article 5 — the tax remittance side. Investment in tax remittance systems, or purchase of the corresponding software and hardware, for remitting withholding tax, income tax or VAT under section 3 Panaras of the Revenue Code. Its scope runs the opposite way to article 4 — it names tax remittance service providers among those it reaches, rather than excluding them.
• Article 7 — three classes of service fee. (1) Fees paid to providers of e-document preparation or transmission services, electronic certificate fees and electronic data storage (Cloud Storage) fees; (2) the same classes of fee paid to tax remittance service providers; (3) information system assessment fees and related charges paid to the Electronic Transactions Development Agency (ETDA) in order to qualify as a provider of e-document preparation or transmission services.

Article 7(3) and the second paragraph of article 4 look contradictory but are not: one governs spending on your own use, the other the compliance cost of qualifying as a provider. All three share one timing rule: actually paid between 1 January 2026 and 31 December 2027, judged by the payment date, not the date of the contract or the invoice.

03The six conditions have assets as their subject, not service fees

This is why the workbook gives them a sheet of their own. Article 6 opens with "assets under article 4 and article 5 shall…", then lists six: never previously used; depreciable under section 65 bis (2) and acquired and in a condition ready for use according to its purpose by 31 December 2027; located in the Kingdom; used for not less than three consecutive accounting periods counted from the first accounting period in which it was acquired and ready for use; not an asset receiving related tax benefits under other royal decrees issued under the Revenue Code; and not an asset used in a business enjoying corporate income tax exemption under the investment promotion law, the national competitiveness enhancement law for targeted industries, or the EEC law. The last two both end on the same words: whether wholly or partly.

On the subject of the clause, article 7 service fees sit outside article 6 — a fee is not an asset, so it does not carry conditions such as "never previously used" or "three consecutive accounting periods". That is not a small point: a company whose systems turn over within three years has to count the cost of early disposal on the asset side, while the fee side is not bound by it.

But do not read that as "service fees have no threshold". Article 7 confines itself to expenditure for the company's own business, and all three articles hang on the same sentence about the Director-General's notification. So the workbook marks this cell amber: what the clause says is set down as it stands, and whether you can aggregate on that basis is for an adviser to settle, not something to conclude before the notification appears.

04Running both BOI and non-BOI lines: split first, aggregate second

Article 6(6) is a hard limit for a BOI company. Spending on e-invoicing systems used on a BOI-exempt line cannot also take this decree; the clause reads "whether wholly or partly", so a single machine used even in part on an exempt line puts the whole claim at risk of being struck out.

So for a company running both, the order is: attribute the assets to a line first, then decide which part takes the relief. Splitting at filing time is usually too late to assemble the supporting documents — which is why the workbook gives the split a sheet of its own.

Article 6(5) has to be read alongside it: an asset that has already taken related tax benefits under another royal decree issued under the Revenue Code cannot stack this one on top. Together the two limbs say — this relief does not stack with relief from the same source, and does not coexist with an exempt business line.

05Which cells are deliberately left blank

Clause numbers, the period of application and the text of the six conditions are fixed in the decree and can be traced back by clause number, so the workbook gives them. What moves case by case is marked amber:

• Which article your spending falls under — it follows how and why the money was spent, not the description on the invoice.
• The timing and documentation of the claim — the decree hands these to a Director-General notification, and as at our retrieval date no such notification has been seen, so the workbook gives no method of claiming and states no countdown.
• Which business line an asset belongs to — the split between exempt and non-exempt lines follows actual use, not the purchasing department.
• Whether service fees can be aggregated on article 7 alone — the subject of the clause supports the reading, but it needs an adviser to settle against the notification and the facts.
• Whether your company is on the list published by the Director-General — the definition in article 3 confines an "e-Tax Invoice" to one prepared by a registered operator whose name the Director-General has published, a layer that sits outside the relieving provisions and is easily skipped whole.

Which article each item of your spending falls under, which assets have to be split by line first, and whether fees already paid in the first half of 2026 can be picked up, all have to be checked item by item against payment records, asset use and line attribution, and verified against the official text and notification in force before filing.