- The VAT immediate supply of information starts on 1 July 2017 for those who file VAT monthly.
- VAT record books are sent to the tax authority electronically, and those who do so are exempt from several reporting forms.
- Companies concerned must adapt their invoicing systems and internal processes before the start date.
On 15 May 2017 the State Gazette published Order HFP/417/2017 of 12 May, setting the regulatory and technical specifications for keeping VAT record books through the tax authority’s online portal. It is the missing piece for the so-called immediate supply of information, or SII, which takes effect on 1 July 2017. A final provision, on forms 036 and 037, will apply from 1 June.
Instead of filing VAT summaries after the event, the companies concerned will send the tax authority, electronically and within short deadlines, the data on their issued and received invoices, investment goods and intra-EU transactions. It is a change of method with consequences for the systems, invoicing processes and accounting of those who must apply it, and it demands preparation.
Who must apply it and what is sent
Those obliged are taxable persons whose VAT filing period coincides with the calendar month: in practice, large companies, VAT groups and those registered in the monthly refund register. Other companies may opt in voluntarily. The content of the submissions covers the records of issued and received invoices, investment goods and certain intra-EU transactions, with codes defined in an annex.
Data are sent through web services in XML format or through a form on the online portal. Each record must be sent within the regulatory deadline and, if there are technical problems, the order allows an additional submission within four calendar days. Records for the first half of 2017 may be submitted between 1 July and 31 December of that year, which gives some room to get started.
What changes in the VAT return
Companies that keep their books this way are exempt from filing forms 347, 340 and 390, and must include additional aggregate data in the return for the last period of the year. Monthly filing of form 303 continues, within the first thirty calendar days of the following month, and up to the last day of February for January.
The advantage for the administration is having the information almost in real time. For companies, the potential advantage is lighter reporting burdens and a smoother relationship with the tax authority, but at the price of putting data in order and meeting very short deadlines. A format error, a misclassified invoice or a late submission can lead to requests and corrections.
What to review
The companies obliged should already check with their software provider and adviser that the invoicing and accounting system can generate the submissions in the required format, and test it before 1 July. It is also worth reviewing internal processes: who records each invoice, within what time and with what controls, so that the data reaching the tax authority are reliable.
Companies not obliged may consider whether to opt in voluntarily, weighing the cost of adapting their systems against the possible simplification of reporting obligations. In any case, it is a decision best taken with the tax adviser and in good time, not in the last weeks of June.
Changing the method of filing is easier when it is tested before it becomes compulsory.
This article is general information. It is not legal, tax or investment advice, and it does not take anyone’s particular circumstances into account.
