They must not submit billing records for the first semester
The change of position will benefit 36,000 companies

The countdown for the entry into force of the Immediate Information Supply has begun. As of July 1, some 62,000 companies must send the details of the invoices issued and received to the Tax Agency within eight days. It represents the most significant change in VAT management since the tax was introduced. Despite the fact that the project officially enters into force on July 1, the Treasury reported that it will require companies to also deliver the billing records for the first semester with the new SII management programs.

However, the companies attached to the Redeme (Monthly VAT Refund Registry) must not deliver the invoices issued and received between January and June of this year through the SII. Sources from the Tax Agency argue that this group will already provide information on their record books for the first half of 2017 by filling in form 340. Therefore, the Treasury considers that it is not necessary for companies to send the same information through the SII. With this measure, the Treasury addresses the claims of the Redeme companies.

This change of position will be included in the ministerial order that regulates the normative and technical specifications of the SII and that will be published shortly. Currently, you can consult a draft on the website of the Tax Agency. Even so, this text is not definitive and, for example, it does not include the decision to soften the information requirements for companies attached to the monthly refund regime.

The SII will affect large companies –which are those that invoice more than six million euros–, companies registered in the VAT Monthly Return Registry and VAT groups. The companies adhered to the monthly refund regime, whether or not they are large companies, are the only group that should not submit the billing data for the first semester with the SII. Administration sources estimate that the measure will benefit 36,000 taxpayers, 60% of the total number of companies affected by the SII.

Currently there is already a group of companies that are carrying out a pilot test of the implementation of the SII, which will be extended from July and on a mandatory basis. Throughout this year, the deadline for reporting invoices will be eight days. As of 2018, the period will be definitively set at four days. The Tax Agency defends that technological changes allow progress towards a new form of management that will mean that companies will keep their record books through the electronic headquarters of the Tax Agency. And the information will be updated in almost real time with the sending of the billing data of the companies. The companies will not send the invoices, but certain fields of information that include from the date of issue, to the names and surnames or business name of the recipient, the tax base, the type of invoice or the settlement period, among other headings. The register books of issued invoices, received invoices, investment goods and certain intra-community operations will be managed on the website of the Tax Agency.

A VAT draft

The companies have indicated that the change entails a relevant cost insofar as it requires modification of computer applications and represents a radical change in the way in which VAT has been managed up to now. The Tax Agency emphasizes that the SII project will mean the suppression of formal obligations by eliminating models 347, 340 and 390. In addition, from now on and as is already the case in the field of income tax, the Treasury will provide taxpayers with taxpayers VAT tax data to facilitate compliance with their tax obligations. The idea is that in the future a sort of VAT draft can be sent. The implementation of the SII will also mean extending the period for submitting self-assessments to the first 30 calendar days of the month following the reference period. Until now, the limit was 20 days.

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