Deemed supplies break the assumption the Peppol network is built on, which is that every document has a buyer with an address to send it to. A gift above the prescribed threshold, an asset taken into private use, or inventory held at the date a VAT registration is cancelled all create a Taxable Supply under the VAT Decree-Law with no counterparty waiting to receive an invoice. The Guidelines resolve this with a fixed endpoint and a reporting-only transmission path.
One Fixed Endpoint for Every Deemed Supply
For deemed supplies, the buyer electronic address is always 0235: 9900000097. The Guidelines state that the same value applies whatever the identity of the supplier. That constant is the flag telling the network it is looking at a deemed supply.
This makes the endpoint an ERP configuration item rather than a data entry field. Any system that derives the buyer endpoint from a customer master record will need an explicit override path for deemed supply transactions, because there is no customer record to derive it from.
Reporting Without Exchange
Where an invoice in respect of a deemed supply is not issued to a recipient, there is no exchange of Electronic Invoices at all. The only transmission that occurs is the report to the FTA by the supplier's ASP. Corner 3 and Corner 4 of the five-corner model drop out of the flow, and the document travels from the supplier through its own ASP to the Authority.
The obligation survives the absence of a counterparty. A business that treats deemed supplies as an internal VAT return adjustment, posted through a journal entry with no invoice document behind it, has no transaction to transmit and therefore reports nothing. The output tax still appears on the return, and the corresponding Tax Data does not appear in the FTA's records.
What Counts as a Deemed Supply
The Guidelines anchor the scenario to Article 11 of the VAT Decree-Law on cases of deemed supply, read with Article 12 on the exceptions. The worked examples given are supplies for no consideration, including free-of-charge supplies and gifts exceeding the prescribed threshold, the private use of business assets or inventory, and goods and services owned by a Taxable Person at the date the VAT registration is cancelled.
Scenario 2 does not apply to Commercial Invoices. Deemed supply is a VAT construct, and a Person who is not registered for VAT has no deemed supplies to report.
Where the Exposure Sits
Marketing samples, staff gifts, promotional stock and asset write-offs to personal use are typically recorded outside the sales cycle. They are booked as expenses, inventory movements or disposals, and the VAT treatment is applied at return preparation by the tax team reviewing the general ledger. That process ends at a figure on the VAT return, with the billing system sitting entirely outside it.
Under Electronic Invoicing, each of these transactions has to become a document that the ERP can generate, tag with the deemed supply transaction type, address to the fixed endpoint and hand to the ASP. The design question is which process creates that document and who is accountable for it, given that the underlying event usually originates in operations rather than in finance.
The practical step is to inventory the transaction types the business currently treats as deemed supplies, trace where each is recorded today, and decide which of them will be generating structured invoices by the time the mandate applies.