SII SpainThe Immediate Supply of Information system (SII Spain) came into effect on July 1, 2017, with retroactive effect for the first semester of 2017, obligating companies to send details of invoices issued and received electronically to the Electronic Office of the Spanish Tax Administration Agency.

Who does this measure affect?

  • Large Companies (volume of operations equal to or greater than € 6,010,121.04).
  • Companies that are registered in the monthly VAT refund Scheme (REDEME).
  • Those who apply the scheme of the group of entities included in Chapter IX Chapter of Title IX of the VAT Law.
  • Companies that voluntarily decide to subscribe to this system.

What record books need to be kept?

  • A record book of issued invoices.
  • A record book of received invoices.
  • A record book of investment goods.
  • A record book of certain Intra-Community operations.

What are the deadlines for providing invoicing data?

Data will not be processed on Saturdays, Sundays or national holidays in any of the following cases.

1. Issued invoices

Four calendar days, counted from the date of issuance of the invoice.

Eight calendar days, in the case of those invoices that were issued by the recipient or by a third party.

2. Received invoices

Four calendar days, counted from the accounting record of the invoice and, in any case, before the 16th day of the month following the tax settlement period.

In the case of import operations, four calendar days counted from the accounting record that shows the fee settled by customs for import operations.

3. Certain intra-Community operations

Four calendar days, from the moment of the start of the dispatch or transport, or where appropriate, from the moment of the receipt of the goods to which they refer.

4. Information on investment goods

Within the submission period corresponding to the last settlement period of each calendar year.

Do sanctions apply in the case of non-compliance with the established deadlines of the SII Spain system?

Failure to comply with these terms can be penalised with a fine of 0.5% of the amount of the invoice subject to registration.

However, when the delay refers to the Record Book of issued invoices and received invoices, a quarterly minimum of 300 Euros and a maximum of 6,000 Euros will apply.

In the case of delays relating to the Record Books of investment goods and certain intra-Community transactions, the sanction will be fixed at 150 Euros.

How does it affect VAT returns, models 303, 347 and 390?

Taxpayers under the SII Spain system are not required to submit information statements 347 or 390. However, the Model 303 self-assessments must be submitted on a monthly basis, with the exception of those companies voluntarily subscribing to the SII regime, which, according to the regulations that will come into force on July 1, 2018, may maintain the quarterly basis by which they were previously governed.

In summary, once the information is held by the Tax Agency, companies can compare their information with that of their suppliers and customers in the Agency´s database, which will provide a very powerful tool for financial, accounting and fiscal control.

The Immediate Supply of Information on VAT system (SII Spain), is now underway and future adjustments are expected. In the future, it promises to expand VAT obligations to all taxpayers, allowing VAT refunds to be streamlined.

Peter Spiller

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