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Comments on the New System for the Immediate Supply of VAT Information (SII)

Salvador Balcells i Iranzo's picture

On July 1, 2017, the Immediate Information Delivery System (SII) will enter into force. This basically consists of the electronic sending of information relating to invoices issued and invoices received. Consequently, the SII is not a system for the remission of invoices, but for the transmission of information on invoicing. Although, as indicated, the entry into force takes place from July 1, 2017, during the second half of that year the taxpayers covered by the new system must also submit the information corresponding to the first half of 2017.

Although the detail of the billing records must be sent within four days (through the Electronic Office of the Tax Agency), during the first half of the system, there will be an extraordinary time limit for sending the information, which will be eight Days (in the calculation of both terms are excluded Saturdays, Sundays and national holidays).

The SII will be obligatory for taxable persons with the obligation to self-assess VAT monthly, that is:

  • Large companies (turnover> 6 million Euros)
  • VAT groups
  • Registered in the REDEME (VAT Return Monthly Record)

The persons covered by the SII may submit and enter their periodic VAT self-assessments until the 30th of each month (ten days later than usual) and shall no longer be obliged to submit the models 347, 340 and 390 from the second Half of 2017 (therefore, it should be noted that despite being obliged to provide the information corresponding to the first semester, during the same period, they must continue to submit regular periodic information, especially model 340).

The information to be submitted will be as follows:

  • Log book of invoices issued.
  • Number and, where applicable, serial number appearing on the invoice.
  • Date of issue and completion of operations if different from the previous one.
  • Name and surname, or company name, and VAT number of the consignor.
  • Tax identification in the country of establishment of the recipient of the invoice if different from Spain.
  • Tax base, tax rate and total amount of the transaction.
  • Type of invoice issued (complete, simplified - which with certain requirements may still be grouped - or rectifying)
  • Purpose of the invoice (description of operations)
  • In the case of replacement invoices, the amounts replaced with the new invoice shall be included.
  • Tax assessment of transactions included in the invoice issued:
    • Do not fasten, fasten, fasten and free,
    • Deliveries of goods or provision of services.
    • Classification of the operations object of the invoice issued according to the special Regime or one of the modalities of operation with tax implications.
  • Invoice record book.
  • Number and, where applicable, serial number appearing on the invoice.
  • Date of issue and completion of operations if different from the previous one.
  • Name and surname, or company name, and VAT number of the consignor.
  • The tax identification in the country of establishment of the recipient of the invoice if different from Spain.
  • Taxable base.
  • Supported rate, deductible and total amount of the operation.
  • Object of the invoice.
  • Classification of the operations object of the invoice received in function of the special Regime to which they are received or in their detector in attention to one of the defined modalities of operation with transcendence tax.
  • Record Book of investment goods.
  • Book of certain intra-Community transactions

The sending of the information can be done by two means:

  • Shipment through "Web service" (ie the shipment is made from the billing system itself).
  • By completing a 'web form' (perhaps thought for those taxpayers with low volume of operations).

The new system will not support presentation with file import.

In the case of individuals who voluntarily opt for the SII, this option will imply that their self-assessment obligation will be monthly and that they must also remain in the system at least during the calendar year for which the option is exercised.

The option for the application of the SII must be made during the month of November prior to the beginning of the calendar year in which it must take effect through model 036, but the option for 2017 may be made during the month of June of this year.

The option will be understood as extended for the following years until its application is waived.

The resignation must be made through model 036 in the month of November prior to the beginning of the fiscal year in which it was effective.

For taxable persons enrolled in the REDEME who do not wish to apply the SII, it is planned to approve by a future Order (which will also regulate the detail of the computer characteristics of the presentation, and which will therefore allow the technical adaptation to the SII) Extraordinary to exercise the resignation that is estimated to cover between May and June 2017.

As indicated above, taxpayers applying the SII from 1 July 2017 will also be required to submit the billing records for the first half of 2017 for the period from 1 July to 31 December 2017.

On the other hand, it should be noted that the deadline for sending invoices has changed since January 1, 2017, when the addressee is an entrepreneur or professional acting as such, must be made before the 16th day of the following month. The one in which the accrual of the Tax has occurred (according to the modification introduced in article 18 of Royal Decree 1619/2012, of November 30, which approves the Regulation regulating billing obligations). So far, this deadline was one month from the date of issue of invoices.

Finally, the General Tax Law introduced in its article 200 the provision of penalties for the delay or failure to present the aforementioned formal obligations.

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Salvador Balcells i Iranzo's picture

One of the things Mr. Balcells like most about his job is when you get a safe, legal and fair tax situation for the sake of the taxpayer's tranquility and economy, both in previous structuring and planning, and when certain criteria have to be defended before Tax administration.

As a lawyer, he always try to put himself in the place of the one who asks for advice, so that all the options or alternatives that are considered as solutions, are those that would adopt at a personal level if the interested party is himself.