SII – Electronic Submission of Accounting data
SII obligations in Spain
As from 1 July 2017 the Spanish tax authorities have introduced a system for the immediate supply of accounting information to the tax authorities. The submission of accounting data via this platform is mandatory for all taxpayers filing monthly VAT returns, i.e.:
- Companies registered with the REDEME (Monthly Refund Scheme)
- Large businesses with a turnover above 6,010,121.04 €
- VAT groups
There is also the possibility to opt in voluntarily for the SII with a minimum tie-in period of the corresponding calendar year. Taxpayers subscribed to the SII must provide the tax authorities with the electronic invoicing record of the following Books:
- Book of Invoices issued
- Book of Invoices Received
- Book for Certain Intra-Community Transactions
- Book of Investment Goods
The Information will be sent electronically via a Web service using XML-files for communication. These XML-files can be created by using an extension of your ERP-system or by using a third-party software solution. Furthermore, there is the option to use an online form for a small number of transactions. At Marosa we have developed a Software solution for the SII submission process where you provide us with your accounting information via a template and we will convert your information into the format required, submit it to the Spanish tax authorities and provide you with the response of the Spanish tax authorities"
SII due dates in Spain
The SII information has to be submitted in a time frame of four calendar days, more precisely:
Book of RecordsDue date
Invoices issuedWithin four calendar days after the entry into the accounting system
Invoices receivedWithin four calendar days after the entry into the accounting system
Certain Intra-Community TransactionsWithin the four calendar days of the date of dispatch or transport or, if applicable, from the date of receipt of the goods in question.
Investment GoodsWithin the filing period of the last settlement of the year (up to 30th January)
The term of four calendar days excludes Saturdays, Sundays and national holidays."
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SII penalties in Spain
The fines for a delay are calculated as 0.5% of the invoice amount in the record, with a quarterly minimum of 300 € and a maximum of 6000 €.
SII impact on VAT return in Spain
The Spanish tax authorities require the data submitted via the SII platform to match the information of the VAT returns. It is important that all your SII data reported during the month reconciles with your VAT return reported on a monthly basis. If there are differences, these should be resolved so all data is aligned. In order to show all transactions in a given period in the CSV downloaded from your online account, you will need to tick on the option "Exportacion sin límite". Marosa may assist you producing this request and converting the reply from the tax authorities into Microsoft Excel. We can also help you reviewing the reconciliation made by the tax authorities and taking the relevant actions with your suppliers and customers.
Review the data exported
Once you have downloaded all invoice listings reported during a given period, you can check if they have been reconciled by the tax authorities against your suppliers and customers in the last column (header: "Estado cuadre"). You can get four possible messages:
- "Contrastada": The invoice has been reconciled against data reported by your supplier or customer under the SII system.
- "No contrastada": The invoice has not been reconciled against data reported by your supplier or customer under the SII system.
- "Parcialmente contrastada": Only part of the information has been reconciled against your supplier or customer data under the SII system.
- "No contrastable": The invoice cannot be reconciled because the supplier or customer are not the SII system.
We also recommend checking under column "Estado" if there are invoices accepted with errors ("aceptada con errores"). In these cases, such entries should be corrected to change the status into "Correcto". Please note that reconciled information is only informative. Only the data reported in your VAT return is considered final and your VAT payment must reconcile with your VAT return. In the following links you can find additional information as published by the Spanish tax authorities:
- How is the reconciliation process carried out?
- Can you double check the information reported by suppliers and customers?
- Is the SII data impacting your periodic VAT return?