Is downloading / exporting accounting software data to EXCEL deemed a "DIGITAL LINK" for MTD purpose ?
No. But if the exported data in the spreadsheet includes all the transactions for the return, a digital link between that and the other accounting software is not required.
Per VAT Notice 700/22:
"HMRC will also accept digital links as:
XML, CSV import and export, and download and upload of files"
It is my opinion, not to argue with you because you're perfectly right, but just as an aside here, that the statement made just after that: "HMRC does not consider the use of ‘cut and paste’ to select and move information, either within a software program or between software programs, to be a digital link." is directly contradictory to the part you quote.
Exporting the figures to a spreadsheet, then sticking that in some other software to file the return, is semantically identical to a 'cut and paste'.
My original point is you don't need to consider that terribly written and largely pointless section of the VAT notice if you ensure that the spreadsheet from which you file the return has the original transaction level data on it, because the spreadsheet is then fundamentally identical to the underlying data and is properly digitally linked to the return.
Your original software version is then an additional copy of the data, rather than the source, and doesn't have to be digitally linked to anything.
Please elaborate how you consider cut and paste to be the same as download and import? Baffling.
The underlying arguments are about mapping. In fact HMRC will accept the use of the clipboard as long as it involves mapping the data rather than cut and pasting individual numbers. They describe it as automated.
Most of the MTD-compliant bridging software will do exactly that; download from your software into Excel so as long as you're using an approved supplier you're fine.
Just as a slight diversion, does anyone know how long these bridging solutions will be accepted? I remember someone from HMRC telling me a while back that it would only be during the first year (soft landing period) but I'm not sure if that has now changed.
The limit is about digital links. I am not aware of any suggestion that a bridging solution will ever become not valid.
All software has an element which processes the data from the accounting system and passes it to HMRC. There is no requirement that all the software has to come from one supplier.
For example there some people running their accounts on an IBM ISeries. The accounting software has been modified to produce a Comma Separated Variables file (a text file where all the variables are separated by ... you guessed it a comma) which then goes into my software to go to HMRC.
I don't think anyone suggests that there is anything that will not be valid about this process in the future.
I have done some videos about digital links if you are interested.