The Immediate Delivery of Information system (SII, Suministro Inmediato de Información) will come into force on 1 July, 2017. This means that all invoicing records, i.e. the information on invoices received and invoices issued, must be electronically delivered to the Spanish Tax Agency. SII is not an invoice delivery system, but an invoicing information delivery system.
VAT taxpayers subject to SII The following are subject to SII:
Large companies (over 6 million euros turnover)
Companies registered with REDEME (VAT monthly refunding register)
May a company volunteer for SII? Yes, a company may volunteer for using the SII system, but the system must be sustained for at least one year. The company must exercise this option in its tax statement (form 036) in November, prior to the start of the calendar year when SII should take effect, or in its SOB (start-of-business) statement, in which case it will be effective in the current year.
May a company waive SII? Yes, provided the company is not subject to SII by law. Such waiver must be exercised in form 036 in November, prior to the start of the calendar year when such waiver should take effect.
What information must be delivered in SII? Taxpayers under SII must keep the following record books with the Spanish Tax Agency's website (AEAT), by electronically delivering their invoicing information:
Records of issued invoices.
Records of received invoices.
Records of investment assets.
Records of some intra-Community transactions.
For such purpose, companies must provide AEAT with full details regarding invoicing. Such information will then make up in real time the different Record Books.
When must the information be delivered? Issued invoicesWithin 4 days from the invoice's date of issue. However, the time limit will be 8 calendar days for the second half of 2017. In any event, prior to the 16th day of the month following the month of accrual. Received invoices:within 4 days from the date the invoice is entered in the accounting records and before the 16th day of the month following the tax settlement period where the relevant transactions have been included.
How must the information be sent? The information must be sent using one of the following systems:
Via web service, i.e. the information is sent directly from the invoicing system.
By filling out a web form, for companies with a lower transactional volume.
Is there a special deadline to waive REDEME in 2017? For those taxpayers registered with REDEME who do not wish to apply SII, a special deadline has been set at the end of June 2017 to waive SII.
Must companies also deliver the information of the first half of 2017? Yes. All taxpayers applying SII from 1 July, 2017 must also deliver their invoicing records for the first half of 2017 between 1 July and 31 December, 2017.
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