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The Italian, Polish and Spanish authorities passed a series of measures aimed at detecting and combating tax fraud. The aim is to get close to real-time information of company transactions, which will allow the tax authorities to perform a more efficient tax audit and reduce processing time. Companies face business challenges to implement these new requirements.

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Spain

In Spain a new VAT reporting system “Suministro Inmediato de Información” (SII) will enter into force on the 1st of July 2017 that will impact approximately 62,000 companies.

Submit almost real time These companies have to submit electronically to the Spanish tax authorities data from all AP and AR invoices within 4 days after an invoice is either issued or booked. In the first 6 months - as a transitional period - the companies will have 4 extra days (8 days in total) to submit these invoices.

Automated extraction of the invoice data will be essential to meet the new rules in an automated fashion. The required invoice data has to be transformed in the required SII format (XML) and due to the short deadlines for submitting the report it is preferred to do it in the source system where the invoices are captured. For most companies the required data are already available in the SAP system.

When e-submission of invoice data is implemented the administrative burden will also be lowered as only certain tax self-assessments has to be filed and certain cumbersome declarations no longer need to be submitted.

Businesses classified as large companies will have just over 6 months to adopt this new requirement in its processes, controls and systems. It will be a real challenge. Failure to comply in time could result in penalties and increased risk of a tax audit.

We developed a SAP add-on solution by which the e-submission of the required data from AR and AP invoices is fully integrated in SAP without an external interface or use of external software.  With this add-on the submission of the requested invoices can be done automatically and in time.

Poland

Companies selling across European Union borders have to submit EC Sales List (ESL). This should contain the details of sales or transfers of goods and services to other VAT registered companies in other EU countries summarized per VAT registration number. The tax authorities in the EU use the listings to check whether VAT is declared by the parties involved in cross-border transactions (e.g. no mismatches).

VAT Smartform PDF In Poland a specific extra local requirement applies. As of 1 January 2017 taxpayers making transactions with EU members will be required to submit mandatory the declaration in electronic format.

The aim is earlier identification of possible abuse. The summarized amount per VAT registration number for the sales of goods, acquisition of good and services need to be reported separately to the authorities in PDF.

The Polish tax authorities provides a VAT Smartform PDF that a company has to fill in with the requested information. That Smartform is mandatory and must be used to meet the requirement. Without automation support the data has to be entered manually by the company.

Entering data is a time consuming process. Besides the impact on internal resources, such manual activity increases the risk of data errors, i.e. with entering the VAT registration numbers in the Smartform.

Stricter penalties apply for individuals involved in tax fraud and penalties are introduced for taxpayers who do meet the legal requirement of submitting declarations in electronic format.

We offer a new SAP add-on solution that creates automatically the VAT Smartform from SAP. When our SAF-T SAP add-on solution has been purchased this additional functionality will be managed under SAF-T cockpit as a different report.

Italy

Quarterly informative report VAT invoices data 

Starting from 1 January 2017 a new informative report of VAT data related to AP and AR invoices, including related credit and debit notes and customs bills, has to be filed by taxpayers on a quarterly basis (former Spesometro).

This new report should include the following data:

  • The parties involved in the transaction: VAT number, name, address, fiscal representative
  • Date and reference number of the invoices
  • Taxable basis, VAT rate and VAT amount
  • Type of transaction, reason of VAT exemption
  • For correction invoice the reference to the reported original invoice

The deadline for filing will be the last day of the second month following each calendar quarter (e.g., 31 May 2017 for the first quarter of 2017). Penalties apply in range from a minimum of € 2 to a maximum of € 1,000 per quarter will be imposed for any omission or incorrect filing of each invoice.

Quarterly VAT calculations data report

As of 1 January 2017, on a quarterly basis the figures for calculating the periodical VAT settlements - periodical VAT calculations as well as VAT calculations showing a VAT credit - have to be reported and submitted electronically. The deadline for filing will be the end of the second month following the each calender quarter (e.g., 31 May 2017 for the first quarter of 2017).

The tax authorities will perform a consistency check between the data reported and the VAT payments made. In the case of inconsistencies, penalties could apply from a minimum of € 500 to a maximum of € 2,000 for submitting an incomplete or inaccurate report.

We offer a new SAP add-on solution by which the quarterly informative report can be submitted timely via our integrated SAP solution in an automated fashion. We can provide support as well with implementing the right processes and controls of the quarterly VAT calculations.


More detail also including an overview of the requirements for Lithuania, Norway and Poland and the challenges companies need to overcome when SAP is run can be found in attached slide deck.


SAP add-on solutions for SAF-T 


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Published by Richard Cornelisse
 Richard LinkedIn

Richard advises multinational businesses in improving the efficiency and effectiveness of their Indirect Tax Function and Tax Control Framework.

He started his career as a manager at Arthur Andersen and then became a partner in EY where I led the indirect tax performance team for Netherlands and Belgium. Currently he is a senior managing director of Phenix Consulting.

Richard has over 20 years’ experience advising clients on international VAT issues. He is specialized in the tax aspects of financial transformations, shared service centre migration, and post merger integration work. Richard is also somewhat of a mentor, giving back to the profession. If you are interested in conversation and discussion, please feel free to contact him.