SILICIE: Immediate Submission of Special Tax Accounting Records in Spain

The Immediate Submission of Special Tax Accounting Records (SILICIE) is the system developed by the Spanish Tax Agency (AEAT). Since 2020, it has mandated that companies involved in manufacturing or sale of goods subject to special taxes must manage their accounting electronically via the AEAT’s online platform.

With the enactment of Royal Decree 1512/2018, Article 50 of the Special Tax Regulations was amended, establishing a digital framework that replaces traditional accounting methods for products like tobacco, hydrocarbons, alcohol, and alcoholic beverages. This system allows for real-time, continuous reporting of inventory and product movements subject to special taxes to the AEAT.

Companies Required to Use SILICIE

The owners of the following types of establishments are required to submit their Special Tax records via the AEAT’s Electronic Office:

• Factories
• Tax warehouses
• Fiscal warehouses
• Reception warehouses
• Vinegar factories

Impact on Business Processes

Affected companies will need to adjust certain internal processes to meet SILICIE's technical requirements. The obligation to report product inventories and movements must be done immediately using a structured format, which must be submitted within a set time frame from the moment the product enters or leaves the establishment.

Traditional forms, such as Form 570 (for hydrocarbons) and Forms 553 and 548 (for alcohol derivatives), will be phased out. Under the SILICIE system, the inventory data previously reported in these forms will now be automatically calculated.

How Does SILICIE Work?

Companies are required to submit accounting entries that detail the inventories of products subject to special taxes through the AEAT’s Electronic Office. This obligation also extends to the movement of raw materials used in producing finished goods.

Electronic submission of accounting entries to the AEAT must be completed within 24 hours of a movement occurring. However, in practice, this deadline extends to 4 days, as Article 6, Section 3 of the regulation allows a 96-hour window for companies that record movements, operations, processes, and inventories using a computerized accounting system.

Movements can be reported through three channels:

• Web form: The AEAT offers an online service where taxpayers can manually declare product and raw material movements.
• Plain text file: By uploading a text file with the details of these movements. This file must be manually submitted through the AEAT's approved services
• Web service: Automated submission via an XML file, allowing real-time reporting each time there is an inventory change.

What Information Must Companies Report?

Companies must report the creation of an accounting entry, as well as its cancellation, if a modification is needed. The submission of these entries will follow specific data structures and communication protocols with the AEAT, which may vary based on the type of establishment:

• Alcohol and alcoholic beverages group
• Hydrocarbons group
• Tobacco products group
• Mixed group (alcohol and tobacco products

The AEAT will also provide access to movement and inventory records for each of these groups through the same channels used for submitting the information.

How Do I Prepare My Company for SILICIE?

Adopting SILICIE may require changes to your company’s management systems, especially for businesses with high volumes of transactions involving products subject to special taxes.

The requirement to report a movement within 4 days demands, at a minimum, the development of processes to generate the necessary data in the correct format and timeframe set by the AEAT. It also requires adopting the appropriate technology and systems to communicate with the Tax Agency, ensuring that accounting entries are submitted within the 96-hour deadline.

EDICOM: Your SILICIE Solution

As a leading provider of data integration solutions, EDICOM offers a platform designed to streamline the implementation of the SILICIE system for managing special tax accounting records. Our solution automatically converts data from your management systems into the format required by the AEAT, ensuring accurate and timely reporting of accounting entries. We also manage the communication with the Tax Agency, tailored to the specific group your establishment belongs to. Rigorous testing and validation ensure the information is transmitted with precision and efficiency.