Possible extension of Spanish SII
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.
23 April, 2017
Spanish SII might be extended
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.
Latest changes on data requirements
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):
- Data on imports has been simplified. SAD numbers (números DUA) and date of SAD booking will no longer be required. The number and date of the invoice will apply.
- Where a VAT number has been rejected two times on the grounds of not being registered in the authorities’ database, it will be possible to report this VAT number and invoice with the following details: Clave ID 07 ´No censado´. This will be flagged by the system as ´acceptable error´
- The authorities published the data required for the first semester of 2017. This data is only required from businesses not submitting the Modelo 340. See slide 15 in the below presentation for more details.
- Where you get an error message for a double entry, the authorities will send back a CSV file with details of the originally reported invoice.
- There are further changes on acceptable combination of reporting codes; requirements for companies in TOMS and additional fields where a third party issues the invoice.
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.
Reconciliation of your data
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:
- Reconciled invoice
- Partially reconciled invoice, where the client or supplier is found but details do not match.
- Not reconciled
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.