Spain – SII

A news update (version 0.7) has been published on the website of the Spanish Tax Agency. The main issues are as follows:

1. Answering of technical/legal doubts

Up to the 20th April it was possible to file questions at: sii.gestion@correo.aeat.es . Since this date an ad hoc form is required. Any question addressed to the above email address will be redirected to the form. Answers will be received by email.

2. Expected dates for the implementation of the SII

  • Test phase: January to June 2017.
  • On-line interphase opens since April 2017.
  • Contrast of information possible since May 2017.
  • Start 1st July 2017 (Note).

3. Agreement with software developers

Subject to the signature of a collaboration agreement with the Spanish Tax Agency, the possibility is introduced that software developers are entitled to file SII reports on behalf of its clients. Up to now this possibility was only contemplated as regards the so called “social collaborators” (professional tax advisors).

4. Technical issues

  • Number of positions for “Business name” is extended from 40 up to 120.
  • Capital Assets ledger. Detailed identification of good and period is required.
  • Web service for the uploading of invoices. System will provide the system code (csv) of duplicated invoices.
  • Issued invoices.

          - Erroneous tax identification numbers (NIF). Possibility to feed the system with invoices where the NIF number has been rejected twice due to the same not appearing at the census. A new “IdOtro” code is created to this end (Country code: ES, Code ID: 07. No censado).

          - VAT status. Transaction can be reported both as “subject and not exempt” with or without being eligible to reverse charge.

  • Received invoices.

          - Imports. Specific registers SAD number (número DUA) and accounting register SAD (registro contable DUA) are eliminated. Instead, the same existing fields for invoices (“número de factura” y “registro contable”) are to be used.

  • Data for the first quarter 2017: Only fields that are now declared in form 340 are required.
  • Authorizations for invoicing simplification. New field to inform of the corresponding authorization is included.
  • Special regimes:

          - Travel agencies. Special regime codes 10 and 11 are eliminated. Specific info is to be included as annual report (along with insurance and cash collections).

          - Up to three codes for special regimes could be mentioned:

               o   Issued invoices ledger: Code 07 (cash account) is compatible with codes 01, 03, 05, 09, 11, 12, 13, 14 and 15. / Code 05 (travel agencies) is compatible with codes 01, 07, 11, 12 and 13. / Codes 11, 12 and 13 are compatible with codes 06, 07, 08 and 15.

          - Received invoices ledger: Code 07 (cash account) is compatible with codes 01, 03, 05 and 12 / Code 05 (travel agencies) is compatible with codes 01, 07 and 12

5. Contrast of information

Filed invoices will be typified as eligible for contrast or not. If eligible for contrast three possible statuses would be shown by the system:

  • Contrasted with counterpart.
  • Partially contrasted with counterpart.
  • Non-contrasted with counterpart.

The follow-up period would be 4 months from issuing date.

 

Pablo Lujan
IVA Consulta

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Disclaimer:  The information contained in the present page is general and does not constitute legal advice. Before taking any decision or action on the above information you should take the appropriate professional advice.