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Ensuring Integrity and Compliance: An Overview of Spain’s New Draft Law for Computerized Billing Systems

The Spanish government has introduced a Royal Decree regarding invoicing and Computerized billing requirements. The key points include:

  All billing records generated by the computer systems will be considered as “VeriFACTU invoice issuance systems” or “VERIFACTU Systems.

  The use of computerized billing systems must comply with the requirements set out in the Regulation, which specifies the specifications for computer or electronic systems and programs supporting billing processes. Including guaranteeing integrity, conservation, accessibility, legibility, traceability, and inalterability of billing records.

  The same computerized billing system may be utilized by multiple taxpayers for their economic activities, as long as billing records are differentiated, and all regulatory requirements are met separately for each taxpayer.

  Billing systems must have the capacity to electronically transmit billing records to the Tax Administration securely, correctly, automatically, and reliably.

  Certified Systems must maintain a log of events, automatically collecting interactions, operations, or events during its use, with corresponding data saved for each.

  Responsible declarations from the producer or marketer of the computer system may be requested, and billing records must be signed electronically. The responsible statements of all versions of the computer systems must be saved and preserved.

  The recipient of the invoice, whether a businessman or final consumer, may voluntarily provide certain information to the State Tax Administration Agency by providing data contained in the “QR” code of the invoice.

The following important information was shared regarding the scope of the regulation and its implementation time.

This Regulation will apply to the taxpayers indicated below who use computerized billing systems;

  Corporate Tax taxpayers

  Taxpayers of the Personal Income Tax who develop economic activities

  Non-Resident Income Tax taxpayers who obtain income through a permanent establishment.

  Entities under the income attribution regime that carry out economic activities, without prejudice to the attribution of income that corresponds to their member

Proposed timeline as follows;

– Starting July 1, 2025, only standard SIF or Verifactu-endorsed billing systems are permissible for the creation and submission of invoices by taxpayers within the defined scope.

– Developers and vendors of billing software are required to ensure full adaptation of their products within a maximum time frame of nine months following the approval of the Ministerial Order, which is pending approval and will outline all technical specifications.

This draft law aims to ensure transparency, compliance, and data accuracy in the context of electronic billing systems, contributing to the Tax Administration’s efforts and the overall efficiency of tax obligations.


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