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Inicio » header » New validations in the SII. What changes and how it affects the current version

New validations in the SII. What changes and how it affects the current version

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There are only two months left for the new version 1.1. of the Immediate Information Supply (SII) to come into operation and for the companies that are obliged to present VAT through this system to update their ERP management software. Specifically, as of January 1, 2021 the new version of the SII 1.1. will include new validations and errors. The aim of these new features, according to the Tax Agency, is to improve the quality of the information provided and make management even more efficient.
The communication about these new validations was issued on June 30, 2020, and although the tests started last October, it is not until January 1 next year that they will become operational. It is important to know these new developments because they require the updating of the companies’ accounting modules.
The following validations are exposed to three accounting books: the register of issued invoices; the register of received invoices and the register of certain intra-community operations (sale of goods on consignment).

New validations in the register of issued invoices

Below are the new validations in the register of invoices issued:

Return under traveler’s regime

  • In the A4, A5 or A6 types of communication, the block called Provision of Services cannot be completed.
  • When the type of communication is A4, the date of dispatch cannot be later than 31.12.2018.
  • When the type of communication is A4, the operation date will be mandatory and subsequent to the date of issue.

Total amount

  • If the total amount field is filled in it will be validated to be equal to: Ʃ (BI +Exempt fee + Surcharge fee equiv.) of all the detail lines of the block “Subject/Not exempt” + Ʃ (BI exempt) of all the detail lines of the block “Subject/exempt” + “Amount not subject art 7, 14, others” + “Amount not subject by location rules”.
  • An error of ± 10 euros will be admitted.
  • If it is not fulfilled, error message.
  • It will not be applied when the regime key is 03,05,06 or 09.
  • It will not apply when there has been a billing agreement.

Simplified invoices

  • Breakdown of the quota charged:
    • When the type of invoice is F2, F4 or F5, the field for the amount charged must be equal to the taxable base for the type (a margin of ± 10 euros is permitted).
  • Amount not exceeding 3,000 euros (Art. 4.2 Invoicing regulations):
    • When the type of invoice is F2 Ʃ (BI +Fee) of all the detail lines of the block Subject/Non-Exempt + Ʃ (BI Exempt) of all the detail lines of the block “Subject/Exempt” + “Amount not subject art 7, 14, others” + “Amount not subject by location rules” cannot be more than 3000 euros (a margin of ± 10 euros is allowed).

Insolvency proceedings and totally or partially uncollectible receivables

  • When the invoice type is R2 or R3, the following will be validated.
    • Breakdown: only the breakdown at invoice level will be allowed and the counterpart has to be identified by means of a NIF.

Counterpart Identification Block (I)

  • If the invoice type is F2, F4 and R5, the counterpart identification block cannot be completed. Otherwise the registration will be rejected.
  • If the transmission amount subject to VAT is completed, the invoice type must be F1, F3, R1, R2, R3 and R4.

Counterpart identification block (II)

  • Intra-community deliveries of goods. Identification of the counterpart.
    • When the counterpart is identified through the ‘Others’ block and the identification type is 02, it will be validated that the identification field fits the VAT-NIF structure of one of the MS.
    • When the counterpart is identified through the ‘IDOthers’ block and the identification type is 02, it will be validated which invoice type is F1, R1, R2, R3 or R4.

Counterpart identification block (III)

  • Reverse charge (S2 and S3). Identification of the counterpart.
    • When S2 or S3 is indicated, the counterpart must be identified by means of a tax identification number.
    • When S2 is indicated, the invoice type can only be F1, R1, R2, R3 and R4.
    • When S3 is indicated, the invoice type can only be F1, R1, R2, R3 and R4.

Counterpart Identification Block (VI)

  • Equivalence surcharge.
    • When the field ‘equivalence surcharge’ is filled in, the counterpart must be identified by means of a tax identification number and must be valid. (In particular 07 not registered will not be admitted).

Date of issue and settlement period

  • The date of issue may not be earlier than the date of operation. This validation will not be applied when any of the special regime keys is 14 or 15 or A4 communication type.
  • The year and period must match the year and period of the operation date. This validation will not apply if the invoice type is R1, R2, R3, R5 or in the case of R4 negative. Nor will it apply to F1 invoices issued for the correction of invoices by substitution, option 2 of FAQ 2.8.
  • In the absence of an operation date, the year and period must coincide with the year and period of the issue date. This validation will not be applied if the invoice type is R1, R2, R3, R5 or in the case of negative R4.

Special Regime for Used Goods (SRUG)

  • When only one special regime is marked and this is 03, the ‘not subject’ block cannot be completed.
  • When only one special regime is marked and this is 03, only S1 can be indicated within the ‘Subject/Non-Exempt’ block.

Special investment gold regime

  • When the special regime key is 04, the ‘not subject’ block cannot be completed.
  • When the special regime key is 04, it cannot be indicated.
  • S1 and S3 of the ‘subject/non-exempt’ block.

Special regime of group of entities

  • The field ‘taxable base at cost’ cannot be completed if none of the regime keys is 06.
  • If any of the regime keys is 06, the invoice type must be different from F2, F3, F4, R5.

Special cash flow regime

  • When only one special regime is marked and it is equal to 07, the non-subject block cannot be completed.
  • When only one special regime is marked and it is equal to 07, neither S2 nor S3 can be indicated from the Subject/non-exempt block.
  • When only one special regime is marked and it is equal to 07, the exemption keys E2, E3, E4 and E5 of the exempt block cannot be used.

Operations subject to IGIC/IPSI

  • Cuando se indique una clave de régimen especial y sea igual a 08, sólo podrá cumplimentarse el bloque ‘no sujeta’ por reglas de localización.

Collections on behalf of third parties

  • When the regime key is 10, the invoice type must be F1.
  • When the regime key is 10, the counterpart must be identified by means of a tax identification number. (In particular, the code 07- Unregistered will be rejected).
  • When the regime key is 10, only the block ‘not subject to art 7, 14’ can be filled in.

Local Business Leasing

  • When only one regime is indicated and it is 11, 12 or 13, only the 21% rate will be admitted.

AAPP VAT slope de devengo

  • When only one regime is marked and it is 14, the counterpart must be identified by a NIF starting with P, Q, S or V.
  • When only one regime is marked and it is 14, the type of invoice must be F1, R1, R2, R3 or R4.
  • When only one regime is marked and it is 14, the operation date will be mandatory and subsequent to the date of issue.
  • When only one regime is marked and it is 14, the exempt block cannot be completed.

Invoices prior to inclusion in the SII

  • First half of 2017 and invoices prior to the inclusion in the SII. Key 16.
    • Key 16 may not be used if for the indicated period the taxpayer is included in the SII.

Block Subject/not exempt (I)

  • Equity surcharge
    • If the tax rate is 21%, only 5.2% or 1.75% will be admitted as a surcharge.
    • If the tax rate is 10 % only 1.4 will be admitted as a surcharge rate.
    • If the tax rate is 4 %, only 0.5 % will be admitted as a surcharge rate. Otherwise, a rejection message will be sent.

Block Subject/not exempt (II)

  • Reverse charge of the taxpayer. S2 and S3.
    • Reverse charge of the taxpayer. S2 and S3.

Exempt Block (I)

  • Exemption keys E2 and E3.
    • If only one special regime key is marked and it is equal to 01, the exemption keys E2, E3 cannot be used.

Exempt (II)

  • Intra-community deliveries. E5 exemption key.
    • The E5 exemption key cannot be used within the ‘service provision’ block.
    • When E5 is indicated, the counterpart has to be identified through the block ‘IDOthers’ with the identification type 02.

New validations Received Invoices Logbook

Total amount

  • If the field ‘total amount’ is filled in, it will be validated to be equal to Ʃ (BI +Input fee + Surcharge fee eq. + Clearing amount) of all detail lines of the ‘breakdown’ block + Ʃ (BI +Input fee + Surcharge fee eq. of all detail lines of the ‘breakdown of taxpayer’s investment’ block
  • A margin of error of +/- 10 euros is allowed.
  • If it is not fulfilled, error message.
  • Not applicable if regime key is 03,05,06.

Simplified invoices

  • When the type of invoice is F2 or R5 the field ‘total amount’ cannot be more than 3,000. (+ 10 euros margin of error will be admitted).
  • When the type of invoice is F2 or R5 and the total amount field is not filled in, Ʃ (BI + Supported Fee) of all the detail lines cannot be more than 3,000. (+ 10 euros margin of error will be admitted).
  • When the type of invoice is F4, the sum of the field ‘taxable base’ cannot exceed 6,000. (+ 10 euros margin of error will be admitted).

Shipping dates and settlement period

  • The date of issue cannot be later than the system date.
  • The settlement period cannot be earlier than the period corresponding to the date of issue.

Agricultural Compensations

  • When the regime key is 02, the counterpart has to be identified by NIF.
  • When the regime key is 02, the field ‘compensation amount’ must be filled in.

Special regime group of entities

  • The taxable base field at cost cannot be completed if none of the regime keys is 06.
  • If any of the regime keys is 06 the invoice type can only be F1, R1, R2, R3 or R4.

Special cash flow regime

  • If there is only one regime key and it is 07 the block ‘reverse charge breakdown’ cannot be completed.

IGIC/IPSI

  • When only one regime key is marked and it is 08, the block ‘reverse charge breakdown’ cannot be completed.
  • When only one regime key is marked and it is 08, only the taxable base field can be completed within the ‘breakdown’ block.
  • When only one regime key is marked and it is 08, the field ‘Deductible quota’ has to be 0.

Intracommunity acquisitions of goods

  • When the special regime key is 09 the block ‘reverse charge breakdown’ cannot be completed.
  • When the special regime key is 09, the invoice type can only be F1, R1, R2, R3, R4.
  • When the special regime key is 09, the counterpart must be identified with NIF-IVA. (type of identification can only be 02).
  • When the special regime key is 09, it will be validated that the ‘identifier’ field conforms to the VAT-NIF structure of one of the MS.

Invoices prior to inclusion in the SII

  • Key 14 may not be used if for the period (first half of 2017 and invoices prior to inclusion in the SII. Key 14) the taxpayer is included in the SII.

Imports

  • When the type of invoice is F5 or LC key regime can only be 01, 04, 05 or 08.
  • When the invoice type is F5 or LC the block ‘reverse charge breakdown’ cannot be completed.

Deductible fee

  • If the field ‘wrong surcharge fee’ is filled in, the field ‘deductible fee’ must be zero.
  • If the type of identification is 03, 04, 05 or 06 the field ‘deductible quota’ can only be 0. It will not be applied if the block ‘breakdown of the taxable person’s investment’ is filled in.

Investment property

  • Optional filling.
  • If regime key = 02, investment property cannot be ‘YES’.
  • If there is only one regime key and it is 08, investment property cannot be ‘YES’.

Deduction in subsequent period

  • New field “deduct in later period”.
    • If the fields ‘deduction exercise’ and ‘deduction period’ are completed, the field ‘deduct in subsequent period’ must be ‘Yes’.

Period and exercise of deduction

  • New fields “exercise” and “deduction period”.

New validations Register of certain intra-community transactions (goods on consignment).

Goods in consignment. Owner

  • Block of compulsory completion.
  • The NIF associated with the book holder must be identified.
  • The NIF of the representative of the registration book holder, if included, must be identified.
  • If the NIF of the Registry Book Holder is of a minor (begins with K) the field ‘Representative NIF’ is obligatory and different from the NIF of the holder.

Goods in consignment. Declared record ID block

  • Block of compulsory completion.
  • It consists of three fields: Exercise, Period and IdRegistration.
  • The field ‘IdRegistro’ is the number assigned by the taxpayer to each record submitted. It must uniquely identify each record. (Ex: 2020-01, 2020-02, 2020-03)
  • XX-XXXX ≥ 03-2020. (Effective date of consignment sales. Operations related to 2020 shipments/receipts may be recorded in 2021).

Goods in consignment. Counterpart block

  • Block to be filled in if Type of operation = 01 or 09.
  • Unfilled block if Type of operation ≠ 01 or 09.
  • Only identification through NIF-IVA will be allowed.
  • It will be validated that the identifier field conforms to the VAT-NIF structure of one of the MS.

Goods in consignment. Block substitute initial recipient

  • Block required if type of operation = 02.
  • Unfilled block if the type of operación≠ 02.
  • Only identification through NIF-IVA will be allowed.
  • It will be validated that the identifier field conforms to the VAT-NIF structure of one of the MS.

Left-luggage. Deposit block

  • Block required If type of operation=01.
  • If the deposit block is completed, it must be different from the one identified in the Counterpart block. (only NIF-IVA)
  • If the operation type=01, the field Warehouse address must be filled in. Otherwise rejection message.

Left-luggage. Expedition/reception information block

  • Block required if type of operation = 01 or 02 or 09.
  • If the type of operation=01: all the fields in the shipping and receiving information block must be filled in, except for the substitution date field.
  • If the type of operation=02, only the fields description, quantity and date of substitution are mandatory.
  • If the type of operation=09, only the description and quantity fields are mandatory.
  • The substitution date field cannot be filled if the operation key is different from 02. Otherwise rejection message.

Left-luggage. IDRegistration Initial Block

  • Required if the type of operación≠ 01 or 09.
  • It will validate that IdRegistroExpInicial coincides with some IdRegistroDeclared of the holder already existing in the system.

Left-luggage. Final destination block

  • Block required if Type of operación≠ 01 or 02 or 09.
  • Description: required if Type of operación≠ 01 or 02 or 09.
  • Quantity: required if Type of operación≠ 01 or 02 or 09.
  • Operation date: required if Type of operación≠ 01 or 02 or 09.
  • Final recipient block: required if Type of operation = 03 or 04. (only NIF-IVA will be admitted).
  • BI/value: required if Type of operación≠ 01 or 02 or 09.
  • Unit price: compulsory if Type of operación≠ 01 or 02 or 07 or 09.

Left-luggage. Invoicing agreement and succeeded entity

  • NumRegistrationAgreementInvoicing.
    • The registration number must exist.
  • Successor entity.
    • The NIF must be identified.

If you are not yet familiar with this system of keeping the VAT register books, we will answer the main questions you may have.

What is SII?

The Immediate Supply of Information (SII) is a system implemented by the Tax Agency with the aim of modernizing and promoting electronic means in the field of VAT taxation. In this way, it is also intended to prevent tax fraud, since the Tax Agency will obtain the information on transactions almost in real time.

The SII consists of the electronic supply of the invoicing records (issued and received), which are part of the VAT Register Books. To do this, details on electronic invoicing must be sent to the AEAT (by means of web services based on the exchange of XML messages, or, where applicable, by using a web form), with which information the different Registry Books will be configured, practically in real time.

This tax obligation implies the electronic keeping of the following books:

  • Record Book of Expedited Invoices.
  • Record Book of Invoices Received.
  • Registry Book of Investment Goods.
  • Registry Book of Intracommunitarian Operations.
  • Registry Book of Amounts in Metallic.

Who is obliged to have this electronic VAT management system?

Since 1 July 2017, this VAT management system has been compulsory for companies whose turnover exceeds 6 million euros; they are registered in REDEME (Monthly VAT Refund Register) or are under the Special VAT Groups Regime (REGE). The Communities of Navarra, Bizkaia, Guipúzcoa and Álava joined this regulation at the beginning of 2018.

In addition to those that are obligatory, any company can voluntarily take advantage of this new system to improve communication in this area with the Tax Agency. At the end of the year, this group can renounce to this system.

What is the billing registration procedure

The companies obliged to present the registry books through the AEAT’s electronic headquarters must send the detail of the invoices issued and received after each invoice.

Specifically, the information relating to the invoices issued must be sent to the AEAT within four working days; and always before the 16th day of the following month.

In turn, invoices received must be sent within 4 working days following the date on which the accounting record is produced, and as with invoices issued, before the 16th of the following month.

How we can help you with our solutions

At Emiral we have extensive experience in implementing solutions to carry out the procedures required by the Tax Office. And we are already prepared to implement the new validations, always in a personalized way and guaranteeing the maximum protection of the data.

Our team of experts in administrative processes and tax filing adapt the appropriate solution to the volume of information required by each business. In this way, we guarantee that our clients adapt their invoicing to the new regulations, in a simple, fast and centralized way.

One aspect to emphasize is the guaranteed confidentiality of the information, so that the communications with the AEAT are carried out through HTTPS certificates and certificates.

This is how we implement our custom solution in three steps; so that companies that are obliged, or those that have voluntarily accepted this electronic procedure, can carry out the procedures required by the Spanish Tax Agency and the Provincial Council of Gipuzkoa in an agile and secure manner.

Source: Agencia Tributaria

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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