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The Spanish authorities are expected to allow individual extensions of the 1 July deadline on Spanish SII obligations. There are also important changes on the content and data requirements.
For those who did not start with the Spanish SII work yet, you can read about actions required in our to-do list for Spanish SII. If you want to know more about the basics of this obligation, you can read our earlier announcement of the SII.
In the meeting on 20 April between the authorities and entities participating in the pilot project, the Spanish authorities agreed to accept applications of a deadline extension from those companies not prepared for the 1 July deadline. These will be individual applications from businesses having difficulties with system requirements. Because it is not confirmed yet, there is no information about the forms, periods or requirements on this application.
There are pros and cons on this extension. It will give extra time to adapt your ERP system and review your processes, but you will not be allowed to test your data on the testing platform of the authorities which is being closed at the end of June. Given the tax authorities announced a stricter approach on penalties later in the year, companies applying for a delay must ensure that they are fully compliant from day one of their obligation.
Send us an email if you are interested in requesting the deadline extension so we can keep you posted on the steps required.
This week the authorities also announced changes to format and content requirements in Spanish SII. There will be a new set of FAQs published in the coming days. This will be version 7, which is expected to be the final version.
The below changes have already been announced by the tax authorities (see link below):
You can find full details of these changes in the presentation published by the Spanish tax authorities (in Spanish).
In Marosa, we take these changes into account in every consultancy and IT project handled for our clients. We strongly recommend looking at your processes and systems well in advance to avoid penalties and potential audits.
Send us an email if you would like to receive a list of questions potentially affecting your tax processes. You can also contact us if you are interested in our master data template and ERP data completeness check.
As announced in our previous posts, the authorities will reconcile data of your invoices issued and received with data reported by your suppliers and customers. A platform showing these reconciliations will be available in May for the testing data that has been reported so far.
Each of your invoices will be flagged with one of the following:
The reconciliation process will be made during four months following the issuance of the invoice. Your team must review these reconciliations every month before submitting the return, taking a mandatory action on any unreconciled amount that has been outstanding for more than three months.
It is important that you carry a testing phase and data reconciliation before the obligation goes live. To do so, your systems must be adapted in the next few weeks to make sure that you can test your reports during the month of June.
Send us an email if you want to receive the XML structure for the testing platform.