Spanish SII changes in October 2019

Spanish tax authorities published important changes in the SII obligation. The XML schema will not change, but we expect a larger number of files to be rejected as from October. Businesses must ensure that their source data meets the new requirements.

Overview of the changes introduced in Spanish SII files

Please find below an overview of the main changes on the checks made by the Spanish tax authorities:

• These changes only impact the Book of invoices issued and Book of invoices received. Other books such as ´Certain intra-Community transactions´ and ´Book of investment goods´ are not affected by the new checks.
• In the SAD documents reported (´DUA´ in Spanish), the DUA number must match the invoice number of the company issuing the invoice. The authorities will also check that the format of the DUA number is correct.
• The authorities will now check that all net and VAT amounts are consistent with the VAT rate reported in the SII. They will accept a small difference of 10€, but differences beyond that amount will be rejected. For example, you can report a domestic sale at 21% rate with net amount of € 100 and VAT amount of € 21.9, but you cannot report that VAT amount as € 35. This requirement will not apply to the data field ´Deductible VAT amount´, which of course can be lower according to applicable deduction limits. Also, field ´Deductible VAT amount ´ cannot be higher than the VAT amount reported in that invoice.
• Exempt and zero rated transactions must include a VAT amount of zero (or leave it blank). This is the case for intra-Community supplies, used goods and other zero-rated supplies.
• If there is data reported in the VAT amount and net amount, the VAT rate is mandatory. Also, net and VAT amount must have the same sign, you cannot report a net amount as positive and VAT amount as negative (or vice versa) unless certain conditions are met (eg. certain credit notes).
• There are also additional checks on transactions flagged as intra-group and transactions under the simplified agricultural regime (REAGYP).

The Spanish tax authorities published guidance about these changes as part of the complete ´Checks and validations document´. Latest changes have been highlighted in yellow.

As from 1 July, the authorities will also allow you to test files with the new requirements in the testing platform of the their website.

These changes are aimed at improving the quality of SII information received by the tax authorities. The category ´accepted with errors´ requires taxpayers to correct these files within six weeks from submission, but such corrections are often overlooked, leading to questions from the tax authorities and time spent by both, taxpayers and tax authorities, responding and processing these questions. Spanish authorities also have plans to introduce a tool to prepare the draft VAT return automatically, so it is important to ensure that data is accurate when this tool is implemented.

What to do next?

We recommend testing every file sent to the tax authorities during July and August against the testing platform with the new requirements. You should then review the answer from the authorities and take action to avoid penalties for long processing times on error messages received from the tax authorities after October.

What is the risk?

When files are rejected by the tax authorities, these are considered as not submitted. Late filing penalties will apply if you do not take appropriate action within the 4 day time limit.

As communicated last month, SII penalties started applying recently after two years where such penalties did not apply. You can calculate the exact deadline for each invoice in the ´due date calculator´ published by the tax authorities.

How can Marosa help with the Spanish SII?

Marosa has a range of solutions for your SII obligations to adapt to your needs and requirements. We are a tax technology firm with a combination of tax knowledge to advice on the right classification of your transactions and software to ensure that your ERP is capable of meeting the SII obligations.

At Marosa we can convert your usual transaction listing in Excel into the required XML files for Spanish SII. You can also send your files via webservices into our web-based platform. Please contact us if you would like to receive more information about our solution on Spanish SII.