Electronic Invoicing

Spain: New Requirements for Computerized Invoicing Systems (SIF)

Spain: Computerized Invoicing Systems (SIF)

The State Tax Administration Agency (AEAT) is working on a Royal Decree that will approve regulations that establish the technical requirements to be adopted by the Computerized Invoicing Systems (SIF), as well as the standardization of formats of invoicing records.

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Law 11/2021 against tax fraud in Spain

Law 11/2021, of July 9 establishes measures to prevent and combat tax fraud. This includes rules against tax avoidance practices that directly affect the functioning of the internal market. It also amends various tax rules and regulates gambling.

This law obliges companies to work with approved Computerized Invoicing Systems (SIF) that support accounting and invoicing processes. The main objective is to avoid the manipulation of accounting data that would allow double accounting or the alteration of records of the operations carried out. This is intended to prohibit what is known as "dual-use software" or computer programs that allow users to keep "B accounting" to be able to invoice without declaring it. 

The manufacturing, commercialization, and possession of computer programs that do not comply with the specifications required by law will be considered a tax violation. A "dual-use software" is a computer program that allows:

  • Keeping separate accounts
  • Failure to reflect, in whole or in part, the recording of transactions performed
  • Recording transactions other than those recorded in the accounts
  • Altering transactions already recorded in breach of the applicable regulations
  • Not complying with the technical specifications that guarantee the integrity, conservation, accessibility, legibility, traceability, and inalterability of the records, as well as their legibility by the competent bodies of the Tax Administration.
  • It is not homologated. The systems manufactured, produced, or marketed are obliged to do so by the regulatory provision.

Characteristics and requirements of Computerized Invoicing Systems (SIF)

Pending the publication of the Ministerial Order containing the Regulation of the technical requirements, the Draft Royal Decree states that the Computerized Invoicing Systems (SIF) must guarantee the integrity, conservation, accessibility, legibility, traceability, and inalterability of the invoicing records generated by them.

A Computerized Invoicing System (SIF) is considered as the set of hardware and software used to issue invoices by performing the following actions:

  • Entry of billing information by any method.
  • Retain billing information, either by storing it in the billing computer system itself or by outputting it to another computer system
  • To process the invoice information by means of any procedure to produce other results, independently of where this process is carried out, being able to be in the own computer system of invoicing or in another computer system previous remission of the information to the same one by any direct or indirect route.

Event log and ability to send information to the AEAT

According to the Draft Royal Decree, the Computerized Invoicing Systems must implement an event log that records all the interactions made with the software, as well as the operations performed, and the events produced during its use. In turn, the SIFs must also have the capacity to send the system information to the Tax Agency continuously and automatically of all the invoicing records according to the specifications established in the technical regulations of the SIFs.

Deadlines for the implementation of Computerized Invoicing Systems (SIF)

With the latest changes introduced to date in the Draft Royal Decree, the following deadlines are provided for taxpayers and software suppliers:

  • The taxpayers obliged to issue invoices to which the Regulation applies must have their Computerized Invoicing Systems (SIF) operational and adopted before July 1, 2024.
  • Suppliers and marketers of Computerized Invoicing Systems (SIF) must offer their solutions adapted to the technical requirements established in the Regulation within a maximum period of nine months from the entry into force of the Ministerial Order that develops it.

Penalties for suppliers of "dual-use software" and taxpayer users

Any company that does not comply with Law 11/2201 against tax fraud in Spain may be sanctioned. Failure to comply with the law entails two types of penalties, one aimed at suppliers of "dual-use software" and the other at taxpayers who are users of this type of solution.

Companies engaged in the manufacture, production, and marketing of "dual-use software" that allows the manipulation of accounting may be fined up to 150,000 euros, while taxpayers using this type of software may be fined up to 50,000 euros.

The penalties and the obligation to use approved solutions came into force on October 11, 2021, although the Regulation establishing the technical requirements to be adopted by the Computerized Invoicing Systems (SIF) is pending approval. The Tax Agency has communicated that no penalties will be imposed until the official publication of the technical Regulations.

EDICOM prepares to offer its approved SIF solution

The Tax Agency will soon be announcing the technical requirements to be met by the Computerized Invoicing Systems, as well as the different requirements to be met by software suppliers to be certified. The Ministerial Order that will make official the Draft Royal Decree approving the Technical Regulations for SIF is currently pending publication. 

EDICOM is working on compliance with the technical obligations required by Law 21/2021 to offer its clients a SIF solution approved by the State Tax Administration Agency (AEAT).

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