HELPING YOU COMPLYING WITH THE SII IN SPAIN
Spain is one of the 14 EU Member States having, or in the process of it, introduced “Digital Reporting Requirements” (DRR), as described in volume 1 of the report dedicated to the “VAT in the Digital Age” by the European Commission.
SII is just the obligation to electronically provide relevant VAT data referred to issued and received invoices to the Spanish Tax Agency (AEAT), in a certain format and time. Among the possible options, Spain’s SII qualifies as a “Continuous Transaction Control” system following the “real time” modality.
Contrary to what happens in other DRR options, SII does not involve the use of mandatory e-invoices. It is however to be mentioned that, when the intended Spanish e-invoice regulation for the private sector is implemented (foreseen for 2024), reporting obligations resulting therefrom will be integrated within the SII for the case of taxpayers within its scope.
What is SII?
The “Immediate Information Supply”, or SII, refers to the obligation affecting some qualifying taxpayers to electronically file the data contained in their VAT registers at the website of the Spanish Tax Agency on, almost, real time basis.
The Royal Decree 596/2016, of 2 December, for the modernization, improvement and promotion of the use of electronic means in the management of the Value Added Tax. Among other novelties, the obligation to file in almost “real time” basis the data corresponding to all the transactions included at the VAT books introduced the, so-called, “Immediate Information System” or SII. The filing is to be made electronically through the website of the Spanish Tax Agency.
This obligation has been in force since 1st July 2017, although affecting to transactions incurred since 1rst January 2017. It affects companies, resident or not, having to file monthly VAT returns, namely:
Those considered as “large entrepreneurs” for VAT purposes
(turnover in Spain over EUR 6.000.000).
Those applying the so called REDEME
(special monthly VAT refund regime).
Those belonging to
Spanish VAT Groups.
It is also possible a voluntary option for the SII, since companies eligible for this system are excluded from certain formal obligations and given longer dead lines for the filing of VAT returns.
Companies within the scope of the SII are meant to submit at the website of the Spanish Tax Agency the required data in a XML file meeting the standards set by the authorities. The deadline to comply with this obligation is 4 days from the moment the sale invoices are issued or the received invoices are accounted for. The possibility to set up a webserver which automatize the filing procedure is contemplated by the authorities.
Want to know more about SII?
The company may take care of the periodical filing/follow-up of incidences at the website of the tax agency, either manually or, ideally, automating the process through the creation of the required web server. The main ERP’s in the market provide a native SII reporting solution covering these requirements, which normally require the company to be using an updated version of the software.
We can help you:
– Providing external IT/VAT expert support to your IT and financial departments as regards the parameterization of the master data allowing the add on to generate the required SII XML’s files.
– IT/VAT expert support when addressing to the incidences arisen during the filing process or as regards the filed SII reports.
An external add on SII solution to be integrated with the ERP of the company so it is able to generate the required SII reports in XML format which meets the technical requirements of the Spanish tax authorities, do the filing at its website and the follow up of incidences.
This software can be:
- A tax engine which integrates a tool for generating the required SII XML’s files.
- A specialized SII software , such as Platformvat SII, which we have developed for the generation/filing/follow-up of the required SII XML’s files.
We can help you:
- Providing external IT/VAT expert support to your IT and financial departments as regards the parameterization of the master data allowing the add on to generate the required SII XML’s files.
- IT/VAT expert support when addressing to the incidences arisen during the filing process or as regards the filed SII reports.
Both services are included if using our solution Platformvat SII.
Use our SII outsourcing service whereby we take care on behalf of the company of the compliance with its SII obligations. We provide this service by means of our solution Platformvat SII.
Who may be interested in this service:
- Those companies affected by the SII with a small number of transactions may contemplate the outsourcing of such obligation to a third party as an alternative to adopting a “native” or a “bolt on” solution. To this end the company would be able to assure that:
- Routines as set-up so the information is provided to us with the required periodicity (4/8 days following registration at the ERP so to file the information to the authorities and to address to any incidence raised by them).
- The information conforms to the template we will require so to generate the required XML’s.
- Multinational companies that are not established in Spain, as they may be faced by additional difficultieswhen implementing the automation of SII, as may result from:
- Having to deal with language differences between the parties involved.
- The lack of physical presence.
- The fact that their internal master data needs an adaptation so to be able to produce the metadata required by the Spanish tax Agency.
- Unharmonized or out of date software which difficult the use of a standard native solution or add on.
Most likely, automation of SII by these companies will require of the coordinated effort, not only of those Spanish IT service providers offering specific SII solutions , but also of VAT experts/IT consultants with the capacity to provide their support both in Spain and, if necessary, in the country where the company has its IT/Administrative department.
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Responsible: ESTUDIO TRIBUTARIO CANARIAS, S.L.L.
Purpose: Collection of personal data to meet your request
Legitimation: Consent of the interested party
Recipients: No data will be transferred to third parties, except legal obligation
Rights: Access, rectify or delete the data, as well as other rights, as explained in the additional information.
Preliminary SII review
We have adopted a very practical approach when designing our protocol for those new clients looking for a decision of its optimal SII solution and, once decided, the implementation of the same.
In our opinion, those companies newly coming under the scope of the Spanish SII in Spain should carry-out a “preliminary SII review” the aim of which should be to check the status quo of its ERP system from the point of view of its suitability to provide the required SII metadata, regardless of the definitive solution that may be adopted,
Following our approach, the findings resulting such a “preliminary SII review” should allow the company to guaranty that it can start filling the SII reports since the date when from such obligation starts (“interim scenario”), not depending of the fact that a definitive SII solution is implement before such a date (“optimum scenario”).
According to our proposed approach, the company would so have an alternative plan (“interim scenario”) for the case that the decision and implementation of a final solution cannot be achieved before the moment its SII obligations start (“optimum scenario”).
Additionally, the work done on the “preliminary SII review” should not be lost, regardless of the scenario, as it would always help facilitating the implementation of the final solution that is decided.
The carrying out of our “preliminary SII review” will be carried out by a multidisciplinary team of IT/VAT expert professionals with the use of the “wizard module” of our solution Platformvat SII.
The outcome of this review would be a “report” which would allow the company to conclude on two main points:
AS IT IS:
- The capability of the company to implement a SII solution before the date its SII obligations start (the starting date).
- If negative, the capability of the company to adopt an interim solution where SII reports can be generated before the starting date out of the existing data with a minimum of implementation changes.
AS IT WOULD BE:
Decision of the SII solution to adopt (not necessarily before the starting date).
Manuel Pérez de Algaba
Indirect Tax Partner
Indirect Tax Partner