Any SII Spain solution should be implemented on 1 July 2017 as the first mandatory submission is already 8 days later. There are rumours that submission deadline might be delayed but that is still a big uncertainty. The decision that you have to make is whether you accept non tax compliance in the worse case. If that is not acceptable you should buy the right solution and start implementing asap to be compliant in time.
Are we ready?
Our SAP add-on solutions are full End-to End solution and SAP application version independent (standard SAP from version R3 4.6.C onwards). A SAP integrated solution for Spain with a cockpit to select reportable outgoing and incoming invoices, create periodic SII files (envelopes), E-submission of SII XML files and control reports E2E):
- Our objects are developed under /SNI/ namespace which is granted by SAP and therefore no risk of overwriting existing objects
- The Add-on Solution will be sent as external transport file and can be installed via standard SAP transport import tools and change management
- Import of the external transport file will take 1 hour and customization of the full solution can be done within 2 days per environment
- To support the customizing a standard excel sheet with required customization and a guidance document for the customization will be provided
- Main effort is for testing of all different business scenarios in the SAP test environments. Based on experience this will take about 4 weeks. It includes the implementation of bug fixes and company specific business scenarios but as well a company's change management process to get it in production
- The creation and submission of the SII reports could be fully automated in SAP Batch jobs. It is however also possible to do some SII reports (for example the sales invoices) fully automated and other SII reports (for example the incoming invoices) manually
At the moment the contract is signed we immediately release the transports and setup project plan to manage this all in detail. However if you decide to purchase after June 1, 2017, we indeed might also face issues when your own change management process itself does not support a quick transfer from development to production environment.
That is something you need to manage well if that applies. We have backup alternatives when you have started too late (alternative submission) but that is only offered at this stage to clients that have purchased our end solution.
See for more background info: Immediate Supply of Information (SII) in Spain
SAP add on for SII
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. Our SII for Spain is ready and functionality can be demonstrated via our own SAP environment.
The SAP add-on is based on the selection of the VAT relevant transactions from the SAP ledgers. This can be done manually with a new SAP transaction or in an automated way via scheduled batch jobs. The SII relevant data from the selected source transactions are stored in a new customized SII table. That single source ensures your data integrity and consistency. There will be no need for maintenance of multiple systems as it will all be maintained in SAP itself. All reportable SII data are available via a single SAP cockpit which enables easy (tax risk) management of the SII reports.
The best way forward is a demo of our solutions via video conference.
- Richard Cornelisse
FAQ Spain - Immediate Supply of Information (SII)
Published by Richard Cornelisse
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.