It is expected that the Spanish authorities will allow individual extensions of the 1^st July deadline on SII requirements. Officially this has not been confirmed, so at amavat Europe we are working on the basis of no possible extensions to the current calendar. Along with this there are important changes on the content and data requirements.

For those of you who have not started with the SII work yet, we advise you become familiar with those actions. If you require to know more, please do not hesitate to contact our Spanish office to know more about the basics of this obligation.

Extension deadline

A meeting on 20^th April, 2017 between the authorities and entities participating in this pilot project, Spanish authorities agreed to accept applications of a deadline extension from those companies not prepared for the 1^st July, 2017 deadline. Individual applications will be from businesses having problems with system requirements. As it has not been confirmed yet regarding information about forms, periods or requirements on this application.

We believe there are positives and negatives on this extension. Of course it will give additional time to adapt your ERP system and review your internal processes, but unfortunately you will not be allowed to test your data on the testing platform of the authorities, which is being closed at the end of June. Due to the Spanish tax authorities becoming stricter with penalties later in the year, after a recent announcement. Companies applying for a postponement MUST safeguard that they are fully compliant from day one of their obligation.

Up-to-date changes on data requirements

Recently the Spanish authorities also declared changes to format and content requirements in SII. They will also publish a new set of FAQs in the coming days, this will be version 7, which is expected to be the final version.

These changes below have already been announced by the tax authorities:

• If a VAT number has been disallowed twice on the grounds of not being registered in the authorities’ database, it will now be conceivable to report this VAT number and invoice with the following details: Clave ID 07 ‘No censado’. This will be identified by the system as ‘acceptable error’.
• Data on imports will be simplified. The number and date of the invoice will relate and SAD numbers will only be required in a single field instead of two.
• Previously if you got an error message for a double entry, the authorities will send back a CSV file with details of the originally reported invoice.
• The Spanish authorities issued the data necessary for the first semester of 2017. This data requirement is only required from businesses not submitting the ‘Medelo 340’.
• Also there are further changes on acceptable mixture of reporting codes; requirements for companies in TOMS and additional fields where a third-party issues the invoice.

amavat Europe strongly recommends you review your processes and systems well in advance to avoid penalties and potential audits.

Reconciliation of your data

The authorities will merge data of your invoices issued and received, with data stated by your suppliers and customers. A platform showing these reconciliations will be accessible in May for testing data that has been reported so far.

Everyone of your invoices will be highlighted with one of the following:

• Partially reconciled invoice, this would mean the client or supplier is found, but details do not match;
• Reconciled invoice;
• Not reconciled.

This reconciliation method will be made during four months following the issuance of the invoice. Every month your team must evaluate these reconciliations, before submitting the return, taking a mandatory action on nay unreconciled amount that has been unresolved for more than three months.

It is very important that your business carries out a ‘testing phase’ and ‘data reconciliation’, earlier the obligation goes ‘live’. This means your systems must be adjusted in the next few weeks to make sure that you can test your reports through the month of June.

amavat Europe provides a one-stop-shop solution for VAT obligations within Europe. We assist clients with a single point of contact that speaks their language and handles all VAT related issues with a standard and cost efficient approach.

If you have any queries or questions, please do not hesitate to contact amavat Europe.
To find out more information please visit www.amavat.eu