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V2628-17 13 October 2017 · SG de Impuestos sobre el Consumo Criterion in force
IVA · suministro inmediato de información

The accounting record date of an invoice for the SII is the date of entry into the accounting system

A query was made regarding the definition of the accounting record date of an invoice for the Immediate Supply of Information (SII) and whether it may differ from that used in the Public Sector Invoice Accounting Register. The DGT ruled that for the SII, the date is the date of entry into the accounting system, regardless of the date of the journal entry.

The question raised

What is understood by the date on which the accounting record of the invoice occurs in accordance with Article 69 bis 1.b) of the Value Added Tax Regulations, and whether it may differ from the date of the accounting record of the invoice in the Public Sector Accounting Record of Invoices as provided for in Law 25/2013, of December 27, on the promotion of electronic invoicing and the creation of the accounting record of invoices in the Public Sector.

The DGT's ruling

For the purposes of the deadline for the submission of billing records received in the SII, the accounting record of the invoice occurs on the date of entry into the accounting system, regardless of the date reflected in the accounting entry. This date may not coincide with the date of recording the invoice in the Public Sector Accounting Record of Invoices regulated by Law 25/2013.

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