What is SII?

The obligation to file the VAT registers data on real time electronically
The Official Gazette of 6 December 2016 published 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 is introduced (the, so-called, “Immediate Information System” or SII). The filing is to be made electronically through the website of the Spanish Tax Agency.

The obligation, in force since 1st July 2017 (although affecting to transactions incurred since 1rst January 2017) will affect companies, resident or not, filing 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.

Companies are meant to submit the required data in a XML meeting the requirements set up by the authorities, to be directly uploaded at the AEAT’s website every 4 days (exceptionally, 8 days during 2017) . The possibility to set up a webserver which automatize the filing procedure is contemplated by the authorities.

The possibility to set up a webserver which automatize the filing procedure is contemplated by the authorities.

Voluntary option for the SII is also possible, since companies eligible for this system are excluded from certain formal obligations and given longer dead-lines for the filing of VAT returns.

Want to know more about SII?


Native solution

The company is able to generate the required XML out of its ERP following the technical instructions provided by the Spanish tax authorities.

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Also, the company may take care of the periodical filing/follow-up at the website of the tax agency, either:

  • Manually or,
  • Automating the process through the creation of the required web server.

We can help you as regards:

  • External IT/VAT expert support for the re-structuring of the master data of the ERP so to generate the required SII XML’s files.
  • The use of an external web-server SAP native solution along with external IT/VAT expert support for the implementation of the same.
  • Once the SII is in force, external IT/VAT expert support for the addressing to the incidences arisen by the Spanish tax authorities as regards the filed SII XML’s files.

Bolt-on solution

The generation of the required XML/file/follow-up is done through the use of specialized software.

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This software can be:

  • A tax engine which integrates a tool for generating the required SII XML’s files.
  • A specialized SII software for the generation/filing/follow-up of the required SII XML’s files.

We can help you
in case that external IT/VAT expert support is required for the re-structuring of the master data of the ERP so the company can generate the structured data required by the external solution. Also, we can help you if external IT/VAT expert support is required for the addressing of the incidences arisen by the Spanish tax authorities as regards the filed SII XML’s files.

Outsourcing SII

We offer a SII outsourcing service whereby we can take care of the compliance with the SII obligations on behalf of the company.

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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.

When implementing the automation of SII, multinational companies that are not established in Spain may be faced with by additional difficulties as may result from their having to deal with language differences between the parties involved, the lack of physical presence or from the fact that their internal master data need an adaptation so to be able to provide SII data meeting with the specific standards required by the Spanish tax Agency.

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.


Preliminary SII review

As VAT advisors we have had to decide which could be our possible role as regards those new clients looking for a SII solution. On this issue we have decided to adopt a very practical approach when designing a suggested protocol for the implementation of such a SII solution.
In our opinion, those companies affected by the SII should carry-out a “preliminary SII review” aiming to gather the information that would be required to be in a position to decide about the best solution to deal with the new SII obligations. 

Furthermore, its scope should also conform to the objective that, regardless of the definitive solution that may actually be adopted, the findings resulting such a “preliminary SII review” should allow the company to guaranty that it can start filling the SII reports since the 1st of July based (“interim scenario”), not depending of the fact that a definitive SII solution is implement before the 1st July (“optimum scenario”). 

Accordingly, under our proposed approach, the company should still have an alternative plan (“interim scenario”) for the case that such an “optimum scenario” cannot be achieved. 

Additionally, the work done on the occasion of 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 actually decided.

Bearing in mind the objective of our suggested approach, a “calendar” of the tasks that should be covered within the scope of the “preliminary SII review” is to be defined, so the same are carried-out by the company. The outcome of this review would be a “report” which would allow the company to conclude on two main points:

  • The capability of the company to implement a SII solution before the 1st of July.
  • If negative, the capability of the company to adopt an interim solution where SII reports can be generated before the 1st of July out of the existing data with a minimum of implementation changes.

  • Decision of the SII solution to adopt (not necessarily before the 1st of July).

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Please complete the following questionnaire in case you want to receive more information about the possible alternatives to automate the SII and how we can help you:


Manuel Pérez de Algaba
Indirect Tax Partner

Gloria Rodríguez
Financial Manager

Pablo Luján
Indirect Tax Partner

Eder Cruz
IT Manager


SII Outsourcing Service

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