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V2467-19 16 September 2019 · SG de Impuestos Especiales y de Tributos sobre el Comercio Exterior Criterion in force
OTRO · ventas en ruta

Authorisation from the Managing Office required to use automated logs as proof of system unavailability

A query was raised regarding what constitutes an automated and auditable log to justify the inability to communicate the draft transit note for on-route sales. The DGT clarifies that these are systems without human intervention that record communication attempts and errors, but their use requires prior authorisation from the Managing Office.

The question raised

What are the “automated and auditable records” referred to in Article 27.4.b) of the Excise Duties Regulations approved by Royal Decree 1165/1995, of July 7 (BOE of July 28), which serve as evidence of the impossibility of having been able to communicate the draft movement document to the AEAT in the roadside sales procedure.

The DGT's ruling

Automated and auditable records are computer files programmed with pre-established rules that operate without human intervention. They must accurately record the time of each communication attempt and any error messages or lack of response from the AEAT. However, their use to substitute the communication of unavailability requires specific authorization from the Management Office, which will determine whether the request is justified.

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