Real-Time Invoice Reporting (RTIR) Explained
Spain is moving forward with significant updates to its VAT law, focusing on enhancing the transparency and efficiency of the invoicing process for businesses. The Spanish Tax Authority (AEAT) has recently submitted a draft Ministerial Order to the EU Commission. This draft outlines the technical, functional, and content specifications required for Computerized Billing Systems (SIFs) and Verifactu, a real-time invoice reporting system (RTIR). These changes are pivotal for businesses operating in Spain, aiming to streamline compliance and ensure real-time reporting of invoicing activities.
Key Updates and Requirements
1. Background on Verifactu and SIFs The introduction of Royal Decree 1007/2023 mandated that taxpayers adapt their SIFs by July 1, 2025. This regulation allows compliance in two ways:
- Generating and preserving Invoice Registries.
- Using the Verifactu RTIR.
2. Draft Ministerial Order Specifications The draft order submitted by AEAT includes several critical specifications:
- XML Format and Structure: Details the required XML format for keeping and forwarding invoices to AEAT, ensuring standardized reporting.
- Preservation and Forwarding: Specifies methods for preserving and forwarding Invoice Registries to AEAT.
- Event Logging: Outlines the XML format and specifications for maintaining a proper log of events.
- Security Features: Details the requirements for QR codes, hashes/fingerprints, and electronic signatures to ensure data integrity and traceability.
3. Timeline for EU Commission Review The EU Commission has until October 4, 2024, to review and comment on the draft. These comments must be considered by the Spanish authorities before final approval and publication.
Draft Ordinance for Certified Billing Regulations
On January 4, 2024, the Spanish Ministry of Finance published the Draft Ordinance detailing technical and functional specifications for invoicing systems. This ordinance aligns with the standardization of billing record formats as established by Royal Decree 1007/2023. Key additions include:
- QR Codes on Invoices: Invoices must contain a QR code and a line indicating issuance by the VERI*FACTU system when applicable. For electronic invoices, a URL of the QR code must be entered separately.
- Multi-Taxpayer System Management: Allows multiple taxpayers to use a single system, provided it manages billing records and events separately for each taxpayer.
- Certification Process: Billing systems will be certified through a “Declaration of Responsibility for the Computerized Billing System,” meeting the minimum requirements without the need for tax authority assessment.
- Real-Time Reporting: Certified software must transmit billing records to the tax authority in real time (VERI*FACTU) or on demand.
Implementation and Compliance
1. Real-Time Reporting with VERI*FACTU A VERI*FACTU system must consistently send created records to the tax authority in real time. This system will be exempt from specific requirements, such as electronic signatures on billing records, streamlining the compliance process.
2. Event Detection and Traceability The system must detect and record events such as initial installation and commencement of operations as a VERI*FACTU system. Additionally, it must ensure traceability by linking the last five billing records correctly with a specific set of data and characters in the hash.
3. Operational Requirements A computer system can start operating as a VERI*FACTU system at any time but must maintain this operation until at least the last day of the year in which it was initiated.
Spain’s latest VAT law updates, focusing on Verifactu RTIR and SIFs, represent a significant step towards modernizing the country’s tax compliance framework. These changes aim to enhance transparency, streamline processes, and ensure real-time reporting of invoicing activities. Businesses must stay informed and prepare for these updates to ensure smooth compliance.
For a more detailed analysis and to stay updated on these changes, consult the full draft order and related documentation provided by the Spanish Tax Authority and the Ministry of Finance.
