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.