On the occasion of the declaration by the World Health Organization of COVID-19 as an international pandemic, the Government of Spain has been gradually adopting a series of measures of different nature, about which this professional office has been informing you , tending to alleviate the serious effects that it is having on Spanish society, among others, in the health, security, transport and mobility, economy and defense fields.

In the field of Special Manufacturing Taxes, the declaration of the state of alarm, the limitations to mobility and the stoppage of the activity of certain sectors and economic agents, undoubtedly represents a direct difficulty for the effective fulfillment of the obligation of sending of accounting entries. This procedure of sending through the electronic headquarters of the State Agency for Tax Administration, is provided for in article 50 of the Regulation of Special Taxes.

In accordance with the provisions of the fourth final provision of Royal Decree 1512/2018, of December 29, the obligation of electronic supply (SILICIE) of accounting entries by establishments affected by the regulations of Special Taxes, is required with effect from January 1, 2020.

However, in order to facilitate the implementation of the necessary technical and computer systems for the fulfillment of this obligation, the first transitional provision of Order HAC/998/2019 (hereinafter, OM), of September 23, by the regulating compliance with the obligation to keep accounts of the products subject to Special Manufacturing Taxes, established an extended special period for complying with the obligation to supply accounting entries corresponding to the first half of 2020, which may be object of supply during the period from July 1 to September 30, 2020.

However, the sector demanded a longer extension, as well as the extension of the term for the exercise of the option to supply accounting entries through an internal accounting system.

Consequently, OM must be amended to regulate compliance with the obligation of accounting for the products subject to Special Manufacturing Taxes. The period for sending accounting entries for the year 2020 is extended and the option of keeping the accounting through an internal accounting system is made possible.

Thus, last Friday, June 26, 2020, the HAC/566/20201 Order was published in the Official State Gazette, which entered into force on Saturday, June 27. The OM of the accounting books was modified including an extension of the obligation until 2021, so the first mandatory declaration to the SILICIE system must be made as of January 1, 2021, supplying the entries for the year 2020 during the period between July 1, 2020 and January 15, 2021.

Therefore, with this modification, the first mandatory declaration through the SILICIE website will take place from January 1, 2021, with the supply of the entries for the year 2020 and the month of January 2021.

Likewise, for this financial year 2020, the possibility of exercising the option of keeping accounts through an internal accounting system (necessary to take advantage of deferred supply periods) has been expanded until September 30 for those wineries that have not done already.

[1] Attached to this Circular as an Annex document. GO TO PUBLICATION

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