TEI Comments on Order Governing Transition to Spain's Immediate Supply of Information System.

Position:Tax Executives Institute

On July 28, 2017, TEI filed a letter with the Spanish Tax Agency addressing Ministerial Order HFP/417/2017 of 12 May 2017, which contains the legal and technical requirements for maintaining VAT registers in the Spanish Tax Agency's Immediate Supply of Information System (SII). TEI's comments were prepared by TEI's European Indirect Tax Committee, whose co-chairs are Paula Regales and Gorka Echevarria. TEI Tax Counsel, Pilar Mata, coordinated the preparation of the submission.

We write to comment on Ministerial Order HFP/417/2017 of 12 May 2017 (Order) published in the Official Gazette of 15 May 2017, which regulates the legal and technical specifications for taxpayers to maintain value-added tax (VAT) registers in the Spanish Tax Agency's website (the Immediate Supply of Information System or SII). Tax Executives Institute (TEI) is concerned about the short period provided to implement the reporting requirements contained in the Order. We welcome the opportunity to speak with you regarding the comments and recommendations contained in this letter.

About Tax Executives Institute

TEI is the preeminent association of in-house tax professionals worldwide and was founded in 1944 to serve the professional needs of business tax professionals. TEI espouses organizational values and goals that include integrity, effectiveness, efficiency, and dedication to improving the tax system for the benefit of taxpayers and tax administrators. TEI believes it is critical to maintain a dialogue between businesses and revenue authorities when developing VAT rules to ensure such rules are workable and not overly burdensome on business or tax authorities.

TEI's approximately 7,000 professionals manage the tax affairs of over 2,800 companies across all industry sectors around the world. TEI's members are accountants, lawyers, and other corporate and business employees responsible for the tax affairs of their employers in an executive, administrative, or managerial capacity, and continually monitor consumption tax developments around the world. Many of these members' companies have a business presence and/or sell into Spain.


The Order provides details necessary to implement Royal Decree 596/2016 of 2 December 2016 (Decree). The Decree introduced the SII, which is the mechanism for taxpayers to maintain VAT records in the Tax Agency's system on an almost real-time basis, effective July 1, 2017.

More specifically, the Order provides details regarding the...

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