This blog was last updated on September 23, 2019

As informed in previous posts, from 1 of July of 2017, big taxpayers in Spain will be obliged to report invoice data on inbound and outbound invoices to the tax authority under the new SII system.

Taxpayers subject to this system must communicate extracted data from issued invoices within four (4) business days following the moment of issuance. In case of invoices issued by a third party on behalf of the taxpayers, the period is extended to eight business days. Data from received invoices must be communicated within four business days, counted from the date when the posting line is created, and in no event later than the 16th day of the calendar month following the VAT accrual date of such transaction.

The technical specifications published at tax authority’s portal are not definitive. In addition, even though the law mandates the use of XML format to structure the data, the actual technical specifications (schemas) of the field of the information registry specifying the information to be sent are yet to be approved by a ministerial Order that must then be published.

Without definitive technical specification market developments at this point are premature since practical details in the technical specifications might trigger the need to change/adapt the basic legislation.

As the deadline for implementation approaches, taxpayers are still lacking the necessary detailed information that would allow them to make the appropriate changes and decisions in their workflow. Anxiety rises as implementing changes within complex IT environments are not necessarily a simple and fast thing to do, especially considering the possibility of being punished with fines (0, 5% of the total invoice) for non-compliance.

We are following the developments closely and hope for a quick reaction of the Spanish government to approve and launch the final versions of the technical specifications.