Immediate Provision of Information (SII) is a change in the current VAT management system that will take effect on July 1, 2017. Therefore, from July 1, invoices issued and received with the new Established period (now 8 working days in national territory and in 2018 become 4). With the SII, a new system for keeping VAT registration books will be moved through the AEAT Electronic Headquarters, replacing the current method, which has been operating for 30 years. On May 15, the ministerial order was published with definitive instructions, which you can download here:
Immediate Provision of Information
In this way, the invoice registration book should be sent almost immediately, assuming a technical effort on the part of the companies concerned and the advisors, as it represents an important workload.
On the other hand, the Tax Agency justifies the change as an improvement, since it will be possible to draft the VAT returns or to check immediately the information declared by the suppliers, among other things.
Who is required to pay for Immediate Provision of Information?
The new Immediate Supply of Information will be compulsorily applicable to the following taxable persons:
- Companies invoicing more than € 6,020,121.04 per year.
- Registered in the Monthly VAT Return Record (REDEME). Taxpayers enrolled in REDEME who do not wish to apply the SII can exercise a waiver during the month of June 2017.
- VAT groups
It can also be applied to the rest of the subjects who wants to.
Which registration books should be sent to the AEAT?
The following books should be sent electronically through the billing records:
- Record book of invoices issued.
- Record book of invoices received.
- Record Book of investment goods.
- Register of certain intra-Community transactions.
In addition to these records, they should submit information on:
- Invoice data (articles 6 and 7 of RD 1619/2012): NIF, identifications, date of issue, rates, quotas and bases.
- Type of operation: Identified by means of keys and sub-keys (simplified invoice, amending invoice, taxable person’s investment, cash VAT and other special schemes).
- Other information: Deductible quota, billing agreements, cadastral reference number in certain leases of premises of business, etc
When to send billing records to the AEAT?
In the immediate supply of information, invoices sent and received have a deadline of four calendar days from the date of issuance of the invoice and from the date on which the accounting record of the invoice occurs, respectively, to be sent to the AEAT. Certain intra-Community transactions will also have a deadline of four calendar days from the beginning of the expedition or transport or, where appropriate, from the moment of receipt in which they have been included.
In the event that the invoice is issued by the recipient or by a third party, the term is 8 business days.
It is precisely in this section that the most doubts have been generated since the initial publication of this system.
During the year 2017 the term of 4 days has been increased up to 8 days.
In relation to the months of January to June, it is established the obligation to send also the aforementioned Books Registration corresponding to those months before December 31, 2017, except for the taxpayers who have already sent the 340 form (those on the REDEME)
What date should I take into account to report the invoices issued?
As a general rule, the date to be taken into account will be the date of issue of the invoice. But it will also have to be at the date of accrual of the transaction, which does not have to coincide with the issuance of the invoice. Likewise, it will be necessary to always be at the deadline established in the billing regulations to forward the invoices to the recipients that is the 15th of the month following the date of accrual of the transaction.
Let’s see some examples *:
Example 1: An entrepreneur A provides a service to another entrepreneur on August 2, 2017, issuing the corresponding invoice on the same day. The deadline for submitting the registration of this invoice through the SII is 14 August. That is, they do not count Saturdays or Sundays, nor the national holidays and if the deadline falls on Saturday or Sunday, it happens to the following Monday.
Example 2: An entrepreneur A provides a service to another entrepreneur on August 2, 2017, issuing the corresponding invoice on September 13, 2017 (the delivery time ends on September 15). The deadline for submitting the registration of this invoice through the SII ends on September 15 (deadline operates). However, the VAT accrued corresponding to this operation must be settled in the declaration of August 2017.
Therefore, since the Management systems, so far, normally do not take into account the date of accrual of the operation but the date of the invoice to calculate the VAT accrued, which we propose is to leave always invoiced all the operations carried out during a month at the end of the same month . This way, we will avoid having to make adjustments not included in the management programs to carry out the correct settlement of VAT.
Example 3: an entrepreneur makes an intra-Community delivery to a French customer. The beginning of transportation of the goods occurs on October 19 and the invoice is issued on November 15 (last day to issue the invoice in accordance with article 11.2 RD 1619/2012 and date on which the accrual occurs operation). The deadline for submitting the registration of this invoice through the SII is 27 November. Do the same comment here as in the previous case.
What date should I take into account to report the invoices received?
As a rule, the date to be taken into account will be the date the invoice received is entered into the accounting system, is The date on which the invoice is recorded, which does not have to coincide with the date of issue of the same or on the date of its receipt. In this case, it operates the same limit of day 15 but with the Variant of the possibility of deducting the invoice received in different settlement periods, depending on the date in which it is chosen to inform, although also have to indicate the date of issue of the invoice received.
See examples *:
Example 4: an entrepreneur Which receives an invoice on August 9, 2017, decides to deduct and deduct the amount paid in the model 303 of the month of August, proceeding to its accounting record with date of entry into the system on September 13. The deadline for submitting the registration of this invoice through the SII ends on September 15 (deadline operates).
Example 5: An entrepreneur who receives an invoice on August 9, 2017 proceeds to his accounting record with date of entry into the system on October 13. The deadline for submitting the registration of this invoice through the SII ends:
a) On October 16 * if you deduct the invoice in the model 303 of September (operates the deadline). (*) See calculation of deadlines.
B) on October 25 if you deduct the invoice in the October 303 model. In accordance with the above examples, an invoice may be deducted once it has been received and entered in the Invoice Record Book received before the 303 model submission deadline.
However, the deadline to send the records through the SII of the 15th day of the month following the month in which the deduction is made must be taken into account.
Example 6: An accountant registers an invoice received, of which he has no record of the date of receipt. The date of entry into the system is October 13. The deadline for submitting the registration of this invoice through the SII is 25 October. The invoice can be deducted from the liquidation period corresponding to the month of October.
That is, if you want to deduct a bill of one month in the VAT settlement for that same period, you must send that invoice no later than the 15th of the next month. Therefore, if we consider the date of registration of the invoice, this means that in the declaration of a month we can deduct invoices registered during the first 15 days of the following month. Thus, we can choose to record the invoices through the SII And send them during the 4 days following the end of a month, to facilitate the schedule of invoices received or to attend to the date of registration of the invoice and then be able to deduct the invoices registered and sent during the fifteen days of the month Next in the VAT settlement the previous month.
In summary: for all effects, only invoices registered and sent during the current month or during the first fifteen days of the following month can be deducted.
How do you send invoice data to the AEAT?
There are two ways to send:
- Telematically, through Web Services based on the exchange of XML messages, which allow a supply of information Almost in real time.
- Completing a web form for those taxpayers who perform few transactions or when they want to send invoice records in isolation.
If you need advice on the Immediate Supply of Information (SII), contact GM Tax. We are experts in tax matters that involve the Tax Agency. We treat each situation in a unique and professional way, adapting to each case.
* Examples have been obtained from the Frequently Asked Questions issued by the Tax Agency.
