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Ntogka, Eleni
Compliance Officer
Asked a question 2 years ago

I would like to ask for a clarification on FAQ 419 regarding the provision of services to SSI entities. According to FAQ 419: “For the provision of services to, subscription arrangements involving, and progress payments for long-term projects involving SSI entities, U.S. persons may extend payment terms of up to the applicable tenor specified in the relevant Directive from the point at which a final invoice (or each final invoice) is issued… For example, if a U.S. person is providing services for a long-term project involving a Directive 2 SSI entity, and a final invoice is dated December 1, then the SSI entity must pay the invoice within 60 days of December 1 (i.e. the value date of the payment should be not later than 60 days from December 1).” If a US person is providing services to an SSI Dir 2 entity since 1 February 2021 and the final invoice for the services will be issued on the 1st of October 2021, then the SSI entity must pay the invoice within 60 days of 1 October 2021? Or is it that every 14 days as of 1 February 2021, the SSI entity must ensure to pay for the services?

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