Immediate Provision of Information (SII)

What is the SII?

It is a change to the current VAT management system that has been in place for 30 years, moving to a new system for keeping the VAT Record Books through the Electronic Headquarters of the Spanish Tax Agency (AEAT), by means of the almost immediate supply of invoicing records.

In this way, the new SII brings the recording or accounting of invoices closer in time to the actual economic transaction underlying them.

Who is affected by the SII?

The new SII is mandatory for taxpayers who are already required to file monthly VAT returns:

• Those registered in the Monthly VAT Refund Register (REDEME),

• Large Companies (with annual turnover exceeding €6 million), and

• VAT Groups.

The new SII also applies to taxpayers who voluntarily choose to adopt it (by opting in on form 036 in November of the year prior to the year in which it is to take effect).

Basic operation

Taxpayers under the SII are required to keep, via the AEAT Electronic Headquarters, through the electronic submission of invoicing records, the following Record Books:

• Record Book of issued invoices,

• Record Book of received invoices,

• Record Book of investment goods, and

• Record Book of certain intra-Community transactions.

To this end, they must send the AEAT details of their invoicing, with which the different Record Books are configured almost in real time. The submission of this information will be carried out electronically, specifically via Web Services based on XML message exchange. The structure of this submission will include a common header with the information of the Record Book holder, as well as the fiscal year and period in which the operations are recorded. This header will be accompanied by a block containing the invoice content.

The submission of this information will be carried out in accordance with the record fields approved by the Minister of Finance and Public Administration through the corresponding Ministerial Order.

When must invoicing records be sent to the AEAT?

Issued invoices

• Within four calendar days from the date the invoice is issued, unless the invoice is issued by the recipient or by a third party, in which case the period will be eight calendar days.

• In both cases, submission must be made before the 16th day of the month following the month in which the VAT related to the transaction was chargeable.

Received invoices

• Within four calendar days from the date the invoice is recorded in the accounts, and in any case, before the 16th day of the month following the settlement period in which the transactions have been included.

• In the case of import operations, the four calendar days will be counted from the date the document containing the customs-settled VAT amount is recorded in the accounts, and in any case, before the 16th day of the month following the end of the period to which the return refers.

Intra-Community transactions

• Within four calendar days from the start of the dispatch or transport, or, where appropriate, from the receipt of the goods.

Investment goods information

• Within the filing deadline for the last settlement period of the year (until January 30).

• Note: Saturdays, Sundays, and national public holidays are excluded when calculating the four- or eight-day periods mentioned above.

Is the same information currently included in the VAT Record Books required?

No. The requirement is to submit certain information currently found in two different places (VAT Record Books and invoices) to the AEAT Electronic Headquarters, relieving the taxpayer of the obligation to keep the current VAT Record Books. Additionally, certain tax-relevant information that was previously included in forms 340 and 347 must also be submitted.

Advantages for taxpayers under the SII

The new SII offers the following benefits for taxpayers:

• Reduction of formal obligations, eliminating the requirement to file forms 347, 340, and 390, as well as to prepare the VAT Record Books. Taxpayers only need to file the corresponding VAT self-assessments.

• Access to “Tax Data” at the Electronic Headquarters, consisting of a “declared” Record Book and a “cross-checked” Record Book with information from third parties within this system or from AEAT’s database.

• These tax data will serve as a useful tool in preparing tax returns, reducing errors, and providing simplification and greater legal certainty.

• Extension by ten days of the deadline for filing periodic VAT returns.

• Shorter refund processing times, since the AEAT will have near real-time access to information and more data on transactions.

• Shorter audit times, for the same reasons above.

• Fewer information requests, since many current requests seek invoices or data already contained in them to verify certain transactions.