MAN expresses concern over guidelines on E-invoicing

……Tasks  CBN on stakeholders engagement

COMFORT EKELEME

The Manufacturers Association of Nigeria (MAN) has expressed concern over the Central Bank of Nigeria (CBN’s) guideline on E-invoicing, adding that there is a need to give adequate consideration for a stakeholders’ dialogue with a view to addressing the concerns.

Director-General, MAN Mr. Segun Ajayi-Kadir, in a statement made available to newsmen said this development is pertinent particularly for those classes of manufacturers and businesses that would be negatively affected by guidelines.

He said, “We noted that the implementation date on the circular is scheduled for 1st February 2022; whereas the guideline itself was issued on the 21st January 2022.  This is just 11 days of grace before implementation. This is rather hasty.

“A circular on monetary or fiscal guidelines requires adequate adjustment time. This is more so when it involves international trade and transactions; where a minimum of 90 days allowance of time is normally required, as many operators would have opened Form M and concluded deals either for import or export. Straightaway, one must say that transactions already embarked upon before the commencement of the guidelines should be exempted and the commencement date should be extended by a minimum of 90 days.

“Straightaway, one must say that transactions already embarked upon before the commencement of the guidelines should be exempted and the commencement date should be extended by a minimum of 90 days,” he said.

He said that many operators would have opened Form M and concluded deals for international transactions; where a minimum of 90 days allowance of time was normally required.

Ajayi-Kadir added that the new regulation which stated that any Form M bearing a unit price in excess of 2.5 per cent of the verified global checkmate price would not be approved was a concern to manufacturers.

“Besides, we are worried about the determination of global price verification mechanism and benchmark prices. What happens if some companies are able to negotiate better prices due to their scale of order and are able to get competitive lower prices? Will these competitive prices be within the benchmark?

“Clearly, this aspect of the policy will lead to several challenges on valuation down the line including a floodgate of valuation issues with Nigeria Customs Service (NCS),” he stated

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Speaking further, he, however, called for clarification on paragraph D of the guidelines; wherein the CBN directs that “the content of the electronic invoice authenticated by authorised dealer Banks is only advisory for the Nigeria Customs Service (NCS).”

He said, “MAN considers CBN and NCS as agencies of the Federal Government, and hence should harmonise their functions in this regard.

“Otherwise, businesses and indeed our members will be subjected to paying unnecessary and additional FOB upliftment by the NCS. This is in addition to a situation that may arise where the CBN forces such an importer or manufacturer to reduce its price if it is considered not in conformity with the benchmark pricing.

“In paragraph H, the CBN directs supplier and buyers to transmit their authenticated invoices through the CBN appointed service provider to the Nigeria single-window portal. While MAN considers this measure as a step to check perceived malpractices, we believed that the essence of single window policy is being diminished and this could introduce unnecessary bureaucracy with attendant multiple charges.

“The annual subscription fee charge of 350 dollars per authentication by suppliers on the portal meant to maintain the system is a clear disincentive to suppliers of imports to Nigeria, particularly raw materials and spares for manufacturers,” he said