With the experience gained after, almost, three months of helping companies with their SII obligations, we think worthwhile stressing the importance of a very simple routine which many may be tempted to dismiss as unnecessary.

We refer to the convenience to formally check and keep evidence that the data declared by the company at its monthly VAT returns is consistent with the data resulting from the SII registers for the same period.

This routine is especially important at this initial stage when, assumedly, the SII has not been fully automated by companies and, as a result, it cannot be ascertained that all sets of data are fully consistent, namely: the ERP’s accounting data, the SII reporting data and the data that is produced for VAT declaration purposes.

When carrying-out the reconciliation between SII registers and VAT returns, a plus of attention must be paid to those set of data which may be especially problematic for SII reporting purposes, as may happen with those transactions that are to be specifically declared at the following boxes of form 303:

A new updated version of F.A.Q’s has been published at the website of the Spanish Tax Agency to be considered since the 3rd of August. There are new questions added (2.43 and 2.47) as well as an update of some of those already existing.

Given its implications, especial notice must be taken of the new updated version of F.A.Q’s 6.1. that refers to: Transactions which must be included in the “Register of certain Intra-Community operations”.

It must be remember that this Register contains data referred to the physical movement between two member states of the company inventory when there is no a transfer of ownership (the so called “transfers”) or of fixed assets which are to be subject to certain works. No reference to amounts of taxable base or VAT quota is contemplated among those data to be provide at the SII report for these transactions.

At the new version, by way of a new paragraph included at this F.A.Q., the Tax Authorities point-out to the obligation to also include “transfers” at the corresponding Register of Issued or Received Invoices, namely: “For the case that the transaction is documented by an invoice it will also have to be informed at the Register of Issued Invoices or Received as it may correspond”.

The Spanish invoicing ordinance does not make any special mention as to how transfers are to be documented and, we advisors, have been considering that, since not involving two parties nor the transfer of ownership, “transfers” are documented with a pro-forma and not a proper invoice.

Now, however, the company will be obliged to decide if it is actually issuing actual invoices as a document to support its “transfers”, which may be considered to be the case if no special series or numeration is used, nor a special mention that indicated the “pro-forma” nature of the document.

Furthermore, it is perhaps preferable to assume that “transfers” are anyway to be declared at the Registers of Invoices Issued and Received. By doing so, besides avoiding any future problems, the company will be in a position to more easily reconcile its SII Registers with the corresponding monthly VAT return. Until now, this task was complicated by the fact that no reference to the VAT incurred in “transfers” needed to be reported for SII purposes and, so, did not appear at the VAT Registers meanwhile forming part of the periodical monthly VAT returns.

Once the first days from the commencement of the Immediate Information Supply (SII) have elapsed, we want to make an initial assessment based on our experience as providers of SII compliance services to those of our clients affected by the new obligation.

From the outset, our approach as advisers has come from a double consideration, namely:

a)             The difficulties for many companies affected by the SII of being able to implement in time a definitive solution to manage in an automated way the information obligations of the SII, the two possible options being:

The following entry has been published at the heading of SII news in the Spanish Tax Agency website:

“26-06-2017 SII: Term calculator 

In order to provide calculations for the terms for sending invoice registrations through SII, a "Term Calculator" is added in the SII banner in the "General Information" section. This tool indicates the deadline for sending the registrations, as well as the period and year registered in the Register book of issued invoices and in t:he Register book of received invoices for each of the keys of invoices F1 to F6.”

It must be remembered that, during 2017, the dead-line for the submission of the SII reports will be of 8 working days to be calculated: 

Register of Issued invoices: From the date of issuance of the invoice.

The final version of the SII (version 1.0) has been published at the website of the Spanish Tax Agency. The main issues are as follows:

1.       FILINGS IN THE TESTING ENVIRONMENT

The testing environment that has been available from January 2, 2017 will be available indefinitely. 

Between June 19, 2017 and June 30, 2017, version 0.7 and version 1.0 in the XML files are acceptable in the test environment. As of July 1, 2017, only version 1.0 is supported in the test environment. 

2.       FILINGS IN THE PRODUCTION ENVIRONMENT BEFORE JULY 1:

Exceptionally, in order to allow connection tests to be carried out in the production environment, between June 19, 2017 and June 29, 2017, filings can be made in the production environment, but without tax implications.

All invoices received in that period will be physically erased from the production environment on June 30, 2017, which will be closed for that purpose on that day.

All filings made in the production environment, including those sent between June 19 and 29, should carry version 1.0 in the XML files of the various books.