The Immediate Supply of Information (SII) is a new bookkeeping system for VAT, kept via the Electronic Headquarters of the Tax Agency with virtually immediate availability of billing records. In this way, SII allows users to shrink the time window between recording an invoice in accounting and realizing the actual financial operation behind it.
The New SII System
The SII system is mandatory for taxable entities with current obligations to reverse charge VAT monthly. This includes some 63,000 entities:
- Large companies (over €6,000,000 in income)
- VAT groups
- Members of REDEME (Monthly Refund of VAT Registry)
SII is also applicable to taxable entities who voluntarily decide to take part in it (opting in via the 036 model before the November prior to the year in which the model will take effect, or when filing a tax declaration to initiate activity).
Taxable entities who join the SII are required to, via electronic invoice bookkeeping, introduce their records of invoices issued and received into the Tax Agency’s Electronic Headquarters. To this end, they must provide the Tax Agency details of their invoicing; this information will allow the configuration of various record books nearly in real time.
- Record book of invoices issued
- Record book of invoices received
- Record book of investment assets
- Record book of specific intra-community operations within the EU
This information will be transmitted electronically, specifically via web services based on XML message exchange.
The structure of this transmission will have a shared top level: the heading information in each record book, as well as the fiscal year or period in which operations are recorded. This top level is accompanied by a block of invoice content.
This new tax filing system eliminates the obligation to file the 347, 340 and 390 models for taxable entities who use SII, whether due to obligation or opt-in.
Tax Filing Via SII
The mandatory application of this system came into effect July 1st, 2017 for both taxable entities required to join as well as those who opted in. In 2017 alone, invoicing records from the fiscal period from January 1st to June 30th had to be transmitted in the second half of 2017 (from July 1st to December 31st).
- For issued invoices, a period of four calendar days from the date of issue is permitted, unless the invoices were issued by their recipient or by a third party. In that case, the period permitted will be eight calendar days. In both situations, delivery should be completed before the 16th day of the month following the accrual of tax from the operation in question.
From July 1st to December 31st, 2017, the period allotted was eight days.
- For received invoices, a period of four calendar days from the date of the invoice’s accounting entry is permitted, and also must occur before the 16th day of the month following the settlement of the operations in question.
In the case of import operations, the four calendar days must be counted from the date of the accounting entry of the settlement fee corresponding to a customs document. It must also occur before the 16th day of the month following the period referred to in the customs declaration.
From July 1st to December 31st, 2017, the period allotted for received invoices and customs settlement fees was eight days.
Capital assets will only be carried over into the system for those taxable entities subject to pro rata rules. The information they must supply consists of the identification of the asset, start date of asset use, annual pro rata, and annual regularization of deductions. In addition, if the asset is disposed of the company must retire it by noting the disposal invoice as a reference, as well as the corresponding regularization.
This record book will be reported in the final quarter of the fiscal year, or the final period of activity if activity has ceased. The information will be collected in this record book in addition to the record of capital asset purchase and sale, in the Invoices Issued and Received record book.
Regarding intra-community operations within the EU, only two types of operations relevant to Article 66 of the VAT Decree must be recorded:
- The issuing or receiving of goods for the creation of specialized technical reports or work mentioned in Article 70, Section 1, Number 7, of the VAT Law (37/1992).
- The transfer of goods and intra-community acquisition of goods included in Article 9, Section 3, and Article 16, Section 2, of the VAT Law (37/1992).
Intra-community acquisitions and shipments of general goods within the EU must be accounted for in the Invoices Received and Invoices Issued record books, respectively.
Advantages for Your Company
With the new SII system, companies enjoy various benefits:
- The management of bills of sale and bookkeeping of bills of purchase will not undergo any procedural changes.
- Current accounting processes for customer/debtor and supplier/creditor invoices are unaltered.
- High-quality information becomes available in a sufficiently short time period to make the VAT management system more agile.
- Fiscal data retrieval: the taxpayer accesses two record books in the Electronic Headquarters of the Spanish Tax Agency. One is simply “filed records”, and the other “contrasted records”, which provides comparisons of third-party information from those who belong to the system collective, or from the Tax Agency database.
- Taxpayers can compare these various information sources before the end of the tax filing period for their monthly VAT declaration.
- Taxpayers can correct errors made in shipments even if not required by the Tax Agency.
- Reduces the Tax Agency’s information requirements, as many of the current requirements are intended to request record books, invoices or data to verify certain operations.
- Modernizes and standardizes the traditional forms of submitting VAT record books.
- Reduces paperwork requirements, such as the filing of 347, 340 and 390 models.
- Information from the 390 model that cannot be obtained from SII will be supplied as additional information in the 303 and 322 models during the final settlement period.
- Reduces the time needed to finalize refunds, as the Tax Agency gains access to highly-detailed operational information almost in real time.
- Taxable entities included in the new system will have the filing and return period for their monthly VAT reverse charge process extended by 10 days.
Axional ERP/FI – SII performs mapping of invoices and associated taxes in order to convert data into the Tax Agency’s preferred format in the new SII system. This data can be sent to the Tax Agency via a process executed whenever the issuer desires, or via an automatized task in an established period.
Companies should keep in mind that SII possesses a repository of record books to immediately link information from issued and received invoices.
Integration with Axional ERP/FI
To be able to carry out operations with Axional ERP/FI – SII, companies must use Axional ERP/FI to record the various electronic certificates recognized by each company required to file taxes with the SII system. In other words, if a business group managed by Axional ERP/FI contains five companies required to send data to the Electronic Headquarters of the Tax Agency with the SII system, the group must keep records of the electronic certificates recognized for each company. These certificates can be requested from various issuing entities authorized by the Tax Agency of Spain, such as ACCV (Agency of Technology and Electronic Certification), CERES (certification agency of the Royal Mint), CAMERFIRMA (Certification Authority of the Chamber of Commerce), and ANF (National Association of Manufacturers) among others. They may also include autonomous regional entities such as ACCV (Valencian Community Certification Authority), IZENPE (Basque Electronic Certificates and Signatures Corporation), or CATCERT (Catalonian Certification Agency).
In Axional ERP/FI – SII all tax records from various record books are joined together under grouped headings, with the goal of sending data to the Tax Agency’s Electronic Headquarters in the required format. These headings will be generated by each company identified with their electronic certificate, operation type (sale or purchase), issuer (customer/debtor for invoices issued and supplier/creditor for invoices received), date of invoice creation and invoice number. Headings will contain an ID number and serial number.
Axional ERP/FI – SII sends tax records to the Electronic Headquarters of the Tax Agency via either of two options, according to your company’s needs:
- Option 1: Process executed whenever it suits the issuer.
- Option 2: Automatized task sending data at a specified time.
Once the data transmission process has been executed, headings are marked as ‘processed’ based on the confirmation response (or lack thereof) of the Tax Agency’s Electronic Headquarters, in order to avoid the need for retransmission.
Mass transmissions realized through the web services set for each type of record book will return a response indicating both the overall result of the transmission and the specific result of each invoice/record.
Overall Transmission Status
|CORRECT||All invoices in the request have “CORRECT” status.|
|Some invoices in the request have “INCORRECT” status.|
|INCORRECT||All invoices in the request have “INCORRECT” status.|
|CORRECT||The invoice is completely correct.|
|ACCEPTED WITH ERRORS||The invoice contains some errors which did not prompt its rejection from the system.|
|INCORRECT||The invoice contains errors which prompted its rejection from the system.|
If an invoice has the overall transmission status Complete Rejection, or Incorrect status on a Partial Acceptance, the Tax Agency’s Electronic Headquarters will not have recorded it. Axional ERP/FI – SII supports the withdrawal of such billing as well as the management of the correction process.
With regard to transmitted records which the Tax Agency’s Electronic Headquarters has returned as Accepted with Errors, or even those it has returned as Correct, Axional ERP/FI – SII manages and oversees changes before resending the information. The Tax Agency’s Electronic Headquarters will always utilize the most recent modification. Axional ERP/FI – SII possesses supervisory mechanisms which include all possibilities, avoiding errors or duplicates in the management of data transmission and messaging.
Axional ERP/FI – SII also allows users to delete records sent to the Electronic Headquarters of the Tax Agency. Companies must keep in mind that when a deletion order is sent regarding taxes on invoices, the Electronic Headquarters keeps past records of receipt and deletion, and as such no taxes can be resent.
Axional FI-SII Licensing
Licensing in the Axional ERP/FI – SII module uses an annual rental model based on the capacity of the installation server. An additional license is also required for each legal entity, center or branch that provides information to the Tax Agency, as is a license for each platform user in order to better supervise and manage system information.
Based on the capacities of the server in use, as many PVUs as necessary will have to be licensed according to the following table:
|Processor||Maximum Number of Cores/CPUs||PVUs per Core|
|Intel||Up to 2||70|
|Up to 4||100|
|S822LC (IBM Power 8)||Up to 2||60|
|Up to 4||90|
|PVU Price List||66 €|