The so-called “Immediate Information System”(SII) is an obligation introduced by the Spanish VAT regulations from July 2017, which requires companies to submit the content of their VAT record books on the Spanish Tax Agency website, practically in real time (they are given 4 working days to do so).

This obligation is proving quite challenging for companies obliged to comply with the SII requirement, that is to say:

• Companies that submit their VAT declarations on a monthly basis (companies with a business volume exceeding 6 million euros (“large companies”), companies that are members of VAT groups and companies that have opted into the monthly tax return scheme).
• Companies that voluntarily opt to meet the SII obligation.

In practice, the companies concerned find the immediacy with which the SII obligation must be met can be quite a challenge, and as a result the majority will require external support, at least during the transitional period and until they have managed to stabilise their compliance with the SII obligations.  These companies will be required to adopt some or all of the following options to a greater or lesser extent:

• Investing in the automation of the necessary business routines and procedures in order to be able to submit their record books online according to the SII requirements. The internal IT department will more than likely require support from specialised professionals to complete this task.  In order to perform this automation task, it may be necessary for companies to:
• Improve their own information system (ERP), through:
• Improving their ERP parametrisation.
• Developing native solutions,
• Implementing the existing bolt-on solutions in the market.
• Resort to non-native external solutions for the automation of VAT obligations.
• Requesting help from external professionals to comply with their SII obligations and in certain cases, outsourcing compliance with these obligations.
• Increasing the level of automation of their global VAT obligation management routines. 

IVA Consulta can support companies in the automated online submission of their VAT record books, a requirement for companies whose activities fall within the scope of application of the SII. To do this, we help companies choose what we consider to be the best option for automating their SII, and we can also help them with their ERP parametrisation, with developing a native solution, or, alternatively, with selecting and implementing the best external solution. Our multidisciplinary team, which is formed by a member of our firm specialising in indirect taxation and an expert from our technological partner, the Dutch firm TYTHO, work in conjunction with the company’s IT Department or its external IT service provider for this purpose.

Some companies may consider outsourcing compliance with their SII obligations to be the best option, which is why we decided to offer our outsourcing service. Through this service we act on behalf of the company, either on a temporary or permanent basis, to submit their VAT record books online, as well as to resolve any errors and deal with any incidents that may arise as a result of these actions.  Our approach covers the following sections:

• Implementation: In this first phase we gather all the necessary information to establish, in conjunction with the client, the work procedures required in order to meet the SII obligation deadlines, for which:
• We analyse the company’s operations in order to identify standard transactions, business flows, administrative routines and the level of parametrisation of the information system (ERP), we define the SII report model which will be generated using the ERP and which will contain the necessary information to generate the VAT record book files (“SII reports”) that are to be submitted to the Tax Agency.
• The company and IVA Consulta will determine who will perform this work, as well as defining and establishing the periodicity of their respective routines in order to draw up the SII reports and subsequently parametrise these in our PlatformVAT application.
• Compliance with SII obligations: Online submission of the VAT record books on behalf of the company, based on the corresponding “SII reports” provided by the company, and the resolution of any errors or incidents that may emerge in relation to this submission.
• Conciliation: The data corresponding to the VAT record books submitted online to the Tax Agency will be conciliated on a monthly basis as well as:
• The data accumulated for the same period from the “SII reports”.
• The data declared in the monthly VAT declaration, and, where applicable, the recapulative declaration of intra-community operations.
• Monitoring: We will also monitor any incident detected in our work on a monthly basis, as well as identifying opportunities for improvement in the procedures used to obtain data using the ERP and in the level of automation of the SII obligations.

In order to ensure better monitoring of tasks, deadline control and information management, companies will have access to our outsourcing services through our previously mentioned online collaborative work application “PlatformVAT”.