VAT: Immediate Information Supply (SII)

15 May 2017

Since the end of 2014 we have had information that the Tax Agency (AEAT) was working on the so-called “Immediate Information Supply System” (SII), whereby certain taxpayers are to electronically provide their invoicing records. Well, finally, by Royal Decree 596/2016 of 2 December, its entry into force has been approved with effect on 1 July 2017.

The main features of the SII are as follows:

Scope

The new SII will be compulsorily applicable to taxable persons who are currently obliged to self-assess VAT monthly:

* Those registered in the REDEME (VAT Monthly Return Register)
* Large companies (trading volume during the immediate calendar year exceeding 6,010,121.04 euros)
* VAT groups

The new SII may also be used by taxable persons who, voluntarily, decide to avail themselves of it by exercising the option through the corresponding census statement.

Information submitted to the SII

Taxpayers covered by the SII are obliged to keep, through the AEAT Electronic Office by electronically supplying the invoicing records, the following Record Books:

* Record book of invoices issued
* Record book of invoices received
* Record book of investment goods
* Record book of certain intra-Community transactions

The electronic supply of invoicing records will be done through the AEAT Electronic Office using a web service or, where appropriate, by an electronic form, all in accordance with reporting fields to be approved through the corresponding Ministerial Order.

Entities included in the SII, in addition to the information provided by the traditional record books, must include:

a) Record Book for invoices issued:

* Type of invoice, indicating, among others, whether it is complete or simplified.
* Identification, if applicable, of whether it involves record correction (material misstatements).
* Description of transactions.
* Corrected invoices: identification as such and reference to the invoice corrected or, where applicable, any specifications being changed.
* Replacement invoices: reference to the invoice replaced or any specifications being replaced.
* Invoices documenting exempt transactions: reference to the relevant regulations.
* Invoicing per recipient.
* Investment of the taxable person.
* Special regimes: travel agencies, group of entities, etc.
* Transaction settlement period.
* Non-subject transactions, if any.
* Agreements with the AEAT on invoicing.
* Other information to be determined by the corresponding Ministerial Order. 

b) Record Book for invoices received:

* Number and, where appropriate, series, which will replace the receipt number.
* Identification, where applicable, of whether it involves record correction.
* Description of transactions.
* Invoicing per recipient.
* Investment of the taxable person.
* Intra-Community acquisition of goods.
* Special regimes.
* Deductible tax rate for the settlement period.
* Period of settlement in which transactions are recorded.
* Imports: posting date and DUA number.
* Other information to be determined by the corresponding Ministerial Order.

Deadlines for the electronic transfer of invoicing records

* Information concerning invoices issued: Four calendar days from issuance of the invoice; eight calendar days for invoices issued by the recipient or by a third party. In both cases, before the 16th day of the month following that in which accrual occurred.
* Information concerning invoices received: Four calendar days from the date on which the accounting record of the invoice, or the document showing the invoice settled by customs in the case of imports, is produced and, in whichever case, before the 16th day of the month following the settlement period in which the corresponding transactions have been included.
* Information concerning certain intra-Community transactions: Four calendar days from the date of commencement of shipping or transporting, or, where appropriate, from receipt of the goods.
* Information concerning transactions under a special cash-basis regime: Within the general deadlines without prejudice to the information to be supplied at the time of collection or payment.
* Recording corrections: Before the 16th day of the month following the end of the period to which the declaration relates, in which account must be taken.
* Information concerning the record book for investment goods: All records must be submitted within the deadline of the last settlement period.

The deadline of four calendar days is set at eight calendar days for the second half of 2017.

Saturdays, Sundays and national holidays are excluded from the calculation of the deadlines mentioned. Therefore, regional and/or local holidays are deemed calendar days for the purposes of calculating the deadline.

Taxpayers who apply the SII from 1 July 2017 will be required to submit the invoicing records for the first half of 2017 before 1 January 2018.

Deadline for reporting

Statements/settlements corresponding to the persons and entities covered by the SII must be filed within the first thirty calendar days of the month following the corresponding monthly settlement period, or until the last day of February in the case of the statements/settlements for January. Therefore, the deadlines for filing self-assessments will be extended, in general, by 10 days for such taxable persons.

Elimination of other reporting obligations

Taxable persons who apply the SII are exempted from filing the following reporting statements:

* Form 340: affecting statements concerning information to be supplied from the period for July 2017.
* Form 347: will be affected from the period for 2017.
* Form 390: will be eliminated for those subject to the SII pending the publication of the corresponding Ministerial Order.

In addition, those subject to the SII will be able to have the reported tax information through the application that AEAT will provide. Such information will include not only the information reported by the taxable person but will also be compared with the information received from third parties, which will allow taxable persons to verify the information to be included in the corresponding tax returns, with the possibility of correcting any errors committed without need of prior request by the Administration.

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For more information

Susana Arroyo Susana Arroyo

Senior Tax Advisor
HLB Bové Montero y Asociados
Spain

Phone: +34 93 218 07 08

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