Partnerships with economic activities must comply with VERIFACTU requirements

The implementation of the new Billing Regulation (RSIF) raises questions regarding the nature of the computer systems used by various legal structures. Recently, the Dirección General de Tributos (DGT) has clarified the scope of this obligation for partnerships (comunidades de bienes) that carry out economic activities.

What the DGT has ruled

The query concerned whether the use of tools that generate invoices via plugins, but do not automate registration in accounting or tax books, exempted them from complying with the technical requirements of VERIFACTU. The binding body has determined that partnerships are fully included within the scope of application of the Regulation, provided they carry out an economic activity and the billing is performed in their capacity as taxable persons for Value Added Tax (IVA).

The ruling establishes that the computer billing system must guarantee, without exception, the following attributes in the records:

• Integrity
• Conservation
• Accessibility
• Legibility
• Traceability
• Inalterability

The DGT emphasizes that the lack of automation in transferring data to accounting programs or registry books does not constitute an exception to the rule. Compliance with the technical requirements of the Regulation is independent of whether the system generates accounting entries automatically or not.

What this means for you

If you are part of a partnership operating as a taxable person for IVA, your current billing system must be capable of meeting the security and traceability standards required by RD 1007/2023. It is not enough for the software to issue a document with the order details; the system must ensure that the information cannot be altered once generated and that its traceability is complete.

What you should do

It is necessary to verify that the technological tools and billing plugins used by the partnership comply with the technical specifications of the Billing Regulation. The absence of automatic integration with accounting books is not a valid argument for omitting these technical requirements. It is recommended to evaluate the capacity of your current systems to guarantee the inalterability and integrity of tax records.