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V3626-16 31 August 2016 · SG de Impuestos sobre el Consumo Criterion in force
IVA · facturación electrónica

Electronic invoice transformation systems may be used if authenticity, integrity and legibility are guaranteed

A company sought clarification on whether its system for transforming electronic invoice formats (such as from EDI to RosettaNet) using delegated signatures was valid for VAT purposes. The Directorate-General for Taxes (DGT) ruled that this is permissible provided that the authenticity of the origin, the integrity of the content and legibility are guaranteed throughout the entire retention period.

The question raised

Legal validity of this system of issuance, transformation, and custody of invoices for the purposes of Value Added Tax.

The DGT's ruling

Taxpayers may issue and retain invoices in the electronic format compatible with their systems, provided that the authenticity of the origin, the integrity of the content, and legibility are guaranteed. System validation may be carried out through standard management controls that create a reliable audit trail or through prior communication and validation before the AEAT. The lack of prior validation by the Administration does not prevent compliance with the requirements if the taxpayer can guarantee them by other means.

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