FAQ
Is a preliminary thorough economical analysis needed, to answer to the main questions ?
Indeed. The questions to be answered are:
- Are 'closed circuiting' (or 'quasi closed circuiting') credits/debts significant enough to justify the creation of such a system (11)?
In order to possibly decide where to implement a pilot project:
- Which areas (sectoral/geographical) are likely to 'contain' the greater 'concentration' of clearance
opportunity 'closed circuits' ?
Economists, and not only, are invited !
Why would this system be implemented at State / E.U. level ?
The measure, theoretically implementable at private corporations' level (7), could be really effective only if
implemented at State (better, E.U.) level (8), because it needs to have the broader possible reach, and because
MS/the EU could integrate existing services and fiscal instruments / duties, establishing this electronic centralized
platform as binding.
The State/M.S.s/E.U. could decide to involve the banking system or other operators in this mechanisms, in order
to 'outsource' some of the structural costs / fulfillment duties implied in implementing such a massive measure.
Would the system be applicable also to the credits/debts towards the States themselves ?
This is a policy making decision: States could decide to apply this system (mutatis mutandis) to the credits/debts
towards the State itself / M.S.s themselves.
How would the system interact with the registrations for accountancy purposes ?
The system could automatically register all clearances in the system, and ideally upload them on the related invoices / electronic accountancy of each company.
A unified European invoice model document could also be adopted.
Multiple clearing paths possible: how would the system 'choose' ?
When more than one 'clearing path' is possible the system could be programmed for:
equal distribution of the clearance opportunities;
priority systems: the system might be programmed in order to 'choose' the most beneficial clearing path (i.e. the
path which determines the greater 'savings', or avoids the greater damages, to the whole economic system).
More complex for reasons of equal treatment/fairness.
Would partial clearance be possible ?
Of course: it would be registered electronically by the system on the related invoices / electronic accountancy.
Would E.U. backed clearance be possible (State aid rules to be considered) ?
It is a policy decision. In special cases it could be provided for, in several ways.
'Anticipated clearance': when a certain compensation would be possible but one or more invoices would not yet be
due/collectible, the State might wish to intervene in a way to make the clearance possible anyway by anticipating
the amounts (also see next FAQ regarding 'quasi closed' circuits).
What about 'Quasi Closed Circuits'? Would State backed -or assisted- clearance be possible for 'quasi closed circuits'?
In case clearance opportunities are detected as 'close enough' (with criteria to be established at policy making
level), even though a 'closed circuit' is not there because of the lack of one or more links of the chain, the system
could be programmed to permit intervention of the EU (or one or more of the affected MS) by 'filling the gaps'
(i.e. providing -also temporarily- the resources, with substitution then into the creditor/s' position/s).
What about controversial amount clearance ?
In case of any controversy over the amount (with the consequent non confirmation of the preliminary filing) the
invoice would not be part of the clearance system until a (final?) court decision/other legal binding document
would be presented to the competent 'compulsory preliminary filing confirmation for registration purposes office'.
Pending the court decision, this case could also fall within the cases of state backed or assisted clearance (policy
making decision).
What about avoiding risks of duplications/overlapping in payments ?
A due time before and after the clearance hour (ex. midnight Greenwich time each day) is allowed for the system
to cross examine and check all the data available at a given time, while all the new data (including payments)
would be 'frozen' and put in a virtual 'cue' during this time (minutes or seconds, depending on the technology of
the systems).
Payment orders would be withdrawn by the system through automated bank procedures to avoid double payments,
for debts which would have been already cleared by the system during the clearance procedure.
Companies would receive confirmation on which credits / debts (obviously for equal amounts within each other
within each company) would have been cleared by the system.
Would the system have similarities with the existing clearing houses (for ex.) in banking ?
In 'phase 2' of the clearing process the same mathematical model (mutatis mutandis) could be utilized, as also with
clearing houses multiple daily payments of checks and all related operations implying physical transfer of money
are avoided by reciprocal clearances for equal amounts.
Here the focus would not be on avoiding physical transfers (which would represent only the second step of the
implementation process), but to detect 'phase 1' clearance opportunities picking out various groups of (time to
time) unknown subjects to be combined by 'closed circuiting data' within a myriad of (yet) known subjects.
What about the implementation costs ?
The system should be implemented by integrating existing duties/services (tax payers are currently already
inputting their invoices' data into computer-systems), and should be able to avoid a considerable amount of losses
for the economy. It could be thinkable of starting (after an impact assessment) with a pilot project in some areas
(sectoral/geographical) likely to 'contain' the greater 'concentration' of clearance opportunity 'closed circuits'.
Which incentives to full compliance ?
Input of the invoices data -anyway binding- on the system would mean for companies a statistical increase of
payment of their credits/debts.
If coupled with lowering of fiscal pressure (10) able to let companies breath some fresh air, it would enhance
cooperation by conveying the benefits of timely uploading their data in the centralized databases, rather than
create misconception of the new system as an instrument to further burden them. The outcome due to and
increased number of operations, and an increased rate of fiscally 'visible' (and therefore tax collection generating)
ones, could enable States to further lower fiscal pressure, in a virtual circle ideally (instrumental, for e.g., also to
attract more F.D.I.s., etc. etc.).
Would all invoices between companies be part of this mechanism ?
This is a policy issue to be determined, as in theory certain thresholds could be decided in order to lower the
implementation burden: nevertheless, a thorough economic analysis will have to show whether also the smaller
amounts would have a significant impact on cross clearance opportunities.
Could bankrupt companies 'return to operate' through this system ?
Only in theory it could be possible to think of a 'bankruptcy revocation' for those companies that would have not
gone bankrupt should the system have been in function.
The r.o.i. could be not justifiable, considering for ex. that production plants would have been meanwhile either
sold or become obsolete. Nevertheless it could be maybe thinkable of including only 'recent' (ex. within 6 months)
bankruptcies, whose trustees in bankruptcy could be requested to upload the data in a special section (but many
legal technicalities should be considered) of the clearing platform.
Could invoices/fiscal documents between companies and individuals, or between individuals, be part of this mechanism ?
Not for the moment. Yet, a system similar to the current Chinese one (a sort of lottery, which for ex. in Italy could
be more similar to the so popular 'Superenalotto') in a way to stimulate the request for the issuance of invoices by
customers at all levels, as this might turn for them -and maybe, partially, for the issuer himself- into an important
gain in money, could be thought of.