New version of Spanish SII file

Spanish SII: new version of the file

The Spanish tax authorities are introducing big changes in the SII file as from January 2021. This is the biggest update on the SII file since its implementation in 2017. With this update, there will be a greater number of checks and data required in the XML sent to the tax authorities.

Contact our tax technology team to get help on how to implement these changes. This is also a good opportunity to test the Marosa SII solution and start improving your SII data management.

The list below is a summary of the changes introduced in the new XML version. Our explanations take into account the translation into English made in our master file for Marosa SII. If you are not using our tool, we recommend checking the slides and documentation published by the Spanish tax authorities.

As a quick summary: the changes that come into force in 2021 will 1) introduce a new book of invoices for movements of stock under the quick fixes simplification, 2) introduce three new data fields in the book of invoices received and 3) add several data checks in the book of invoices issued and book of invoices received.

SII changes in 2021. Invoices issued (Lhttps://sede.agenciatributaria.gob.es/Sede/en_gb/iva/suministro-inmediato-informacion.htmlRFE)

• Total invoice amount. If this field is populated and the tax relevance code is not 03, 05, 06 or 09, the value for this field must match with the sum of the breakdown of all amounts reported for that invoice. The “total invoice amount” field is mandatory for invoices issued not VAT exempt nor zero rated (code S1) and tax relevance code is 03, 05, 06 or 09.
• Simplified invoices. For the invoices types F2, F4 or R5 the VAT amount field will be mandatory and equal to the net amount multiplied by the applicable VAT rate. The SII will now validate that the sum of all amounts reported is not above 3,000€. Also, customer identification fields must not be completed.
• Rectifying invoices due to bad debt or bankruptcy. The invoice types R2 or R3 will not be compatible when the kind of supply is mandatory. Also, the client must be identified with a Spanish VAT number (so called NIF) to be filed in the “VAT nr” column.
• Property transfer. If “AMOUNT RECEIVED IN PROPERTY TRANSFERS TAXABLE UNDER VAT” field is populated, the invoice type must be F1, F3, R1, R2, R3 or R4.
• Reverse charge. If the reverse charge applies (S2 and S3), the customer must be identified with a Spanish VAT number (so called NIF) and the invoice type must be F1, R1, R2, R3 or R4. Also, tax relevance codes 01, 04, 05, 06, 07 or 12 are acceptable only.
• Specific VAT regime for used goods, art pieces and collection goods. When the tax relevance code is “03”, the invoice amount cannot be reported to “not subject to VAT” fields but “exempt” or “not exempt” fields. For the latter field, the only VAT treatment code accepted will be S1.
• Specific VAT regimen for investment gold. For invoices with tax relevance code “04”, the “Not subject to VAT” column must not be filed. In this case, the VAT treatment codes S1 and S3 will not be acceptable.
• Specific VAT regime for VAT group of entities. For invoices with tax relevance code “06”, the “taxable base at cost” field can be completed. Also, the invoice types F2, F3, F4 and R5 are not acceptable.
• Specific VAT regime for cash accounting. For invoices with tax relevance code “07” related, the “Not subject to VAT” column must not be filed. The invoice treatment types S2 and S3 are not acceptable as well as the exemption reason codes E2, E3, E4 and E5.
• Transaction subject to IPSI/IGIC (Ceuta, Melilla and Canary Islands). For invoices with tax relevance code “08”, the breakdown of amounts will be filled exclusively under the “Amount out of scope according to POS rules” field.
• Funds received via third party. For invoices with tax relevance code “10”, the invoice type must be “F1”, the customer must be identified with Spanish VAT number (so called NIF) and the “amount not subject to VAT due to articles 7 and 14” must be filled in.
• Rental of immoveable property. For invoices with tax relevance code 11, 12 and 13, the VAT rate of 21% will be only accepted.
• VAT pending to be due for invoices issued to Public Administrations. For invoices with tax relevance code “14”, the Spanish VAT number of the counterparty must start with the letter P,Q, S or V and the invoice type must be F1, R1, R2, R3 or R4. Furthermore, the transaction date will be mandatory and must be later than the issue date.  Finally, “exempt” amounts will not be accepted.
• Export of goods. The exempt reason codes “E2” and “E3” are not valid when the tax relevance code is “01”.

Intra-Community supplies:

• The EU VAT number reported will be checked according to the EU formats when the ID type code is “02”. In the same way, the invoice type should be F1, R1, R2, R3 or R4.
• The exempt reason code “E5” will not be valid for intra-Community supplies of services. Also, if the exempt reason code “E5”, the ID type code must be “02”.

Invoice dates:

• The issue date cannot be earlier than the date of the transaction date, except for invoices with the tax relevance codes 14, 15 or type of communication as A4 .
• The reporting period (month and year) must match with the transaction date and issue date, except for rectifying invoices.

SII changes in 2021. Invoices received (LRFR)

• Total invoice amount. If this field is populated and the tax relevance code is not 03, 05, 06 or 09, the value for this field must match with the sum of the breakdown of all amounts reported for that invoice. The “total invoice amount” field is not mandatory for invoices received.
• Reporting period. The reporting period cannot be earlier than the invoice issued date.
• Specific VAT regime for agriculture and fisheries activities (REAGYP). For invoices with tax relevance code “02”, it is mandatory to identify the supplier with a Spanish VAT number. For those invoices, the column “COMPENSATION RATE UNDER REAGYP (Special System for Agriculture and Fisheries)” must be filled.
• Specific VAT regime for VAT group of entities. For invoices with tax relevance code “06”, the “taxable base at cost” field must be blank and the invoice types must be F1, R1, R2, R3 or R4.
• Specific VAT regime for cash accounting. For invoices with tax relevance code “07”, the invoice amounts cannot be reported under the “reverse charge” section.
• Transaction subject to IPSI/IGIC (Ceuta, Melilla and Canary Islands). For invoices under the special regime code “08”, the invoice amounts cannot be reported under the “reverse charge” section. Likewise, the “net amount” field under the “detailed VAT” section must be completed only and the “deductible VAT” must be zero.
• Import of goods. For invoices with invoice type “F5” and “LC”, the tax relevance code must be 01, 04, 05 and 08 and the invoice amounts cannot be reported under the “reverse charge” section.
• Deductible VAT on Specific regimes. If the tax relevance code is 03, 04, 05 o 06, the deductible VAT amount must be zero, except for reverse charge transactions.
• NEW FIELD! Investment good (optional). There is a new optional field intended to identify the acquisition of an investment good. If the tax relevance code is 02 or 08, the field cannot filled in with “YES”.
• NEW FIELD! Deduct in a later period (optional). There is a new field introduced to flag those invoices invoices for which the VAT will be deducted in a later period. If the “Deduction period” and “Deduction year” fields are populated, “Deduct in a later period” field must be filled in with a “YES”.

NEW FIELDS! Deduction period and Deduction year (optional). There are two fields introduced to identify the period when the VAT is deducted.

• xx-xxxx must be later than zz-zzzz, given that:

Year: zzzz
Period: zz
Deduction year: xxxx
Deduction period: xx

• If xx is quarterly or monthly, zz must be quarterly or monthly, respectively, given that:

Year: zzzz
Period: zz
Deduction year: xxxx
Deduction period: xx

• If “deduction period” is populated, “deduction year” must be populated too and vice versa.

Simplified invoices.

• If the invoice type is F2 or R5 and the “total invoice amount” field is populated, the amount reported cannot be above 3,000€.
• Following the above, in case the “total invoice amount” field is not populated, the sum of all the amounts reported cannot be above 3,000€.
• If the invoice type is F4, the net amount cannot be above 6,000€.

Intra-Community acquisitions.

• For invoices under the special regime code “09”, the invoice amounts cannot be reported under the “reverse charge” section.
• Invoice types must be F1, R1, R2, R3 or R4.
• The supplier must be identified by an EU VAT number according to the EU formats and the ID type code must be “02”.

Intra-Community operations. Consignment stock sales (LRDOPI)

As from January 2021, there will be a new SII book to report the information regarding the invoices issued underlying a consignment stock in another EU Member State.

In case you do not have consignment stock transactions, you will not be required to report any information to this SII book.

Please let us know if are interested in receiving further information regarding this new SII book.