Since the Immediate Supply of Information (SII) system entered into force on 1 July, 2017 through Royal Decree 596/2016, of 2 December, improvement actions have been carried out to solve those issues that the standard SAP solution for SII does not contemplate.
This is the case of the invoices issued in the processing of dates, which may cause divergences between the VAT accrual period and the accounting period.
For the purposes of SII, the following are considered:
- Fiscal Year and Period of VAT settlement – tax accrual.
- Invoice issue date – the date that is taken into account for calculating deadlines for sending the information to the Tax Agency (AEAT) (4 days if issued by the issuer and 8 if issued by third parties).
- Operation date – date of completion of the commercial operation.
The standard solution of the SII enables parameterising the date that will give value to the “settlement period” by choosing between Accounting date, Tax declaration date or Document date.
However, the rest of the dates propose a fixed assignment that is not modifiable, so that the “Issue Date” corresponds to the value of the Document Date and the “Operation Date” will be that of the Declaration Date on the SII XML.
The standard process for invoices issued from the SD module means that, at the time of entering the accounting document the Document Date and the Accounting Date will be the same, (from the SD Invoice Date). This causes the Issue Date (document date) to be equal to the Accounting Date.
According to the Invoicing Regulations, issuing the invoice can take place until the 16th of the month following that in which the operation accrued.
That is why the case arises in which a service or delivery of a good has been provided in one month and is invoiced the following month. SAP standard when matching the invoice date with the accounting date, would record the income in the month of issuance of the invoice thus contradicting the accrual principle, which is the criteria set forth as general by article 19.1 of the TRLIS (Consolidated Corporation Tax Law) and according to which the income and expenses will be imputed in the year in which one or the other is produced, in other words, according to the period in which the real flow of goods and services takes place, regardless of when the monetary or financial current derived from them occurs.
To adapt the system to the legal requirements, at Sothis the “Operation Date” is reported in the header of the SD invoice so that, at the time of recording and accounting the invoice, this value is transferred to the accounting document leaving the dates as follows:
- Document date = SD invoice date -> Informed on the Issuance Date of the SII, used for the calculation of the 4 or 8 days if issued by a third party.
- Record date, Tax return date = Operation Date -> Reported as Operation Date of the SII. In this way, the accounting period coincides with the accrual of VAT.
In addition, this Operation Date is used to determine the appropriate number range, since there will be a different one for each month, in this way the numbering breaks in the invoices are therefore avoided, being correlative both in number and time.
The system, at the time of creating the invoice, verifies that for the period of the date of operation there is no invoice with a later date, and if so, it would prevent it from being recorded, and should be modified to be at least equal to the existing one.
Finally, for recapitulative invoices, those that correspond to operations carried out on different dates within the same calendar month, a new field has been created in the SD invoice header called “Date of services from/to”, where the interval in which the operations have occurred would be indicated. This date only has informative effects on the invoice printing form, since it is not sent to the SII.
As a summary, the following example could be shown: an invoice is issued on 15.04.XXXX referring to services provided from 25.03.XXXX to 31.03.XXXX, the dates would be as follows:
- Document date = 15.04.XXXX
- Accounting date = 31.03.XXXX
- Operation date = 31.03.XXXX (Tax return date.)
- Services date = 25.03.XXXX to 31.03.XXXX
The result of the accounting document with the dates of the SII XML would be as follows: