Doctrine by topic · DGT Observatory

Accounting Record: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Stable position Low confidence 10 rulings · 2014–2023

Current position

The accounting record of an invoice occurs on the date it enters the accounting system, regardless of the entry date. Following this record, the information must be submitted within four calendar days, provided it does not exceed the 16th day of the month following the settlement period. In the case of exemptions due to participation, the company must record the securities or rights individually in its accounting records or notes.

The DGT's position does not show a single doctrinal evolution, as the queries address accounting record concepts in different areas (SII, LIS exemptions, and deductibility). Regarding the SII, it has been specified that the accounting record occurs upon entry into the accounting system. Regarding the LIS exemption, the individualized recording of securities is required.

Turning points

  1. V2519-19

    Specifies that the accounting record of the invoice occurs on the date of entry into the accounting system, regardless of the entry date.

Analysis based on 9 of 10 rulings with a stated position. Updated 28 September 2026.

Rulings on this topic

10
V1124-18 30 Apr 2018

Obligation to implement SII depends on turnover exceeding €6,010,121.04

SG de Impuestos sobre el Consumo
suministro inmediato de informaciónvolumen de operacionesperiodo de liquidaciónestablecimiento permanentelibros registro LIVA — Ley 37/1992 del IVA art. 20.1.18LIVA — Ley 37/1992 del IVA art. 104.3
Affects CompanyExpat · Non-residentIndividual

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