Given the different relevant dates for invoicing and accounting records, the purpose of this note is to summarise the main criteria and deadlines that must be taken into account due to their tax implications.
We would like to remind you the importance of correctly identifying the different key dates in the invoicing and accounting processes, as incorrect use may give rise to tax incidents or contingencies.
1. Date of transaction and date of issue.
- The date of the transaction is the date on which the service is provided or the goods are delivered.
- The date of issue is the date on which the invoice is issued.
- When these two dates do not coincide, this must be expressly stated on the invoice.
2. Issuing the invoice.
The legal deadlines for issuing invoices depend on the type of recipient:
- For private recipients, the invoice must be issued on the same day as the transaction.
- For business or professional recipients, the invoice must be issued before the 16th day of the month following the month in which the transaction took place.
3. Registration of invoices in SII.
For taxpayers who keep VAT records through the Immediate Information Supply (SII) system, it is essential to correctly distinguish between the following dates:
- Invoices issued:
These must be registered within a maximum of 4 days of their issue.
- Invoices received:
These must be registered within a maximum period of 4 days from their accounting registration.
- Invoices issued by the recipient or by a third party.
The maximum submission period is 8 days from the date of issue.
Saturdays, Sundays and national holidays are not included in these periods.
For these purposes, the maximum period for the electronic submission of invoicing records must be before the 16th day of the month following the transaction.
4. Computerised invoicing systems (SIF).
- For each invoice issued, the computerised invoicing system immediately generates a registration of the invoice and, where applicable, a registration of the cancellation of the invoice, indicating the hour, minutes and seconds of its generation.
- A computerised invoicing system (SIF) may or may not be VERIFACTU, depending on whether or not it sends the invoicing records to the State Tax Administration Agency (AEAT). However, this will not take effect until 2027.
- These obligations only apply to invoices issued and do not apply to invoices received.
5. Regulatory reference
Invoicing deadline: Royal Decree 1619/2012, of 30 November, approving the Regulation governing invoicing obligations.
SII registration deadline: Order HFP/417/2017, of 12 May.
Computerised invoicing systems and VERIFACTU: Royal Decree 1007/2023, of 5 December.
We are at your disposal for any further questions you may have,
VAT Team - Allyon ETL