From October 2019, a large number of files sent to tax authorities can be expected to be rejected, ever since the Spanish tax authorities published important changes in the SII obligation (although the XML schema will not change), businesses must ensure that their source data meets the new requirements. Here is an overview of the changes on the checks introduced by the Spanish tax authorities:
- These changes only impact the Book of invoices issued and Book of invoices received.
- In the SAD documents reported (´DUA´ in Spanish), the DUA number must match the invoice number of the company issuing the invoice. The authorities will also check that the format of the DUA number is correct.
- The authorities will now check that all net and VAT amounts are consistent with the VAT rate reported in the SII. They will accept a small difference of 10€, but differences beyond that amount will be rejected. For example, you can report a domestic sale at 21% rate with a net amount of € 100 and VAT amount of € 21.9, but you cannot report that VAT amount as € 35. This requirement will not apply to the data field ´Deductible VAT amount´, which of course can be lower according to applicable deduction limits. Also, field ´Deductible VAT amount ´ cannot be higher than the VAT amount reported in that invoice.
- Exempt and zero-rated transactions must include a VAT amount of zero (or leave it blank). This is the case for intra-Community supplies, used goods and other zero-rated supplies. Also, intra-Community acquisitions must indicate a 0 or blank space in the VAT amount.
- If there is data reported in the VAT amount and net amount, the VAT rate is mandatory. Also, net and VAT amount must have the same sign, you cannot report a net amount as positive and VAT amount as negative (or vice versa) unless certain conditions are met (eg. certain credit notes).
- There are also additional checks on transactions flagged as intra-group and transactions under the simplified agricultural regime (REAGYP).
As from 1st July, the authorities will also allow you to test files with the new requirements in the testing platform of their website. Spanish authorities also have plans to introduce a tool to prepare the draft VAT return automatically, so it is important to ensure that data is accurate when this tool is implemented
What does this mean for you?
With these changes aimed at improving the quality of the SII information received by the tax authorities, we recommend testing every file sent to them during July and August against the testing platform with the new requirements. You should then review the inputs from the authorities and take the necessary action to avoid penalties for long processing timelines on error messages received from the tax authorities after October.