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Spanish alcohol, tobacco and hydrocarbon companies to declare stocks electronically as of 2020.

20/05/2019

The project, named as SILICIE, requires companies responsible for products subject to excise duties to disclose every accounting entry with immediate effect.

SILICIE stands for the Spanish phrase “Suministro Inmediato de Libros Contables de Impuestos Especiales,” which means “Immediate Disclosure of Excise Duties Account Books.” Under this system, movements of end products subject to excise duties, and the raw materials used in their production, must be disclosed within a time limit every time stock enters or leaves a warehouse. Thus, bookkeeping will cease to be carried out through analog systems, but will be conducted through an electronic model based on immediate and permanent stock reporting.

The system is similar to the system known as SII (“Suministro Inmediato de Información,” or “Immediate Supply of Information”), which has been in force since 2017 for the electronic declaration of VAT. Inspired by this procedure, the Spanish Tax Agency developed a similar regulatory framework for products associated with excise duties.

Below are some frequently asked questions about SILICIE:

Who is required to adopt SILICIE?

Owners of the following company types will be required to provide their excise duties bookkeeping records through the Tax Agency’s electronic platform:

  • Tax warehouses.
  • Bonded warehouses
  • Receiving warehouses.
  • Vinegar factories.

Will it require affected companies to modify their internal processes?

Some of the procedures previously carried out by the affected companies through analog systems must be carried out through a new digital process, although all product inventory movements will have to be reported immediately. This criterion will pose the greatest challenge for companies, since reporting to the Tax Agency will be based on a structured format regulated by the Tax Agency itself and subject to maximum time limits from the moment the product is recorded as having entered or left the establishment.

The companies’ regular reports to declare operations (form 570 for hydrocarbon companies, and forms 553 and 548 for alcohol derivative companies) will cease to be processed, as the system defined by SILICIE means that the inventory information contained in these forms will be calculated automatically.

When will the SILICIE project be launched?

The project is due to be launched in January 2020.

At this time, some dates have also been established for testing, according to the following calendar:

  • June 1, 2019 - Tax Agency test environment to be made available.
  • September 15, 2019 - Tax Agency production environment to open for testing (which may be performed until December 15, 2019).
  • January 1, 2020 - SILICIE to launch.

How will SILICIE work?

The companies will communicate accounting entries relating to product stocks subject to excise duties through the Tax Agency’s electronic platform. This obligation also affects movements of raw materials used in the manufacture of end products.

The declaration of movements may be carried out through three channels:

  • E-form: The Tax Agency will provide a service through which taxpayers can connect and manually declare product and raw material movements.
  • Plain text format: By filing a text file detailing these movements. This will require the file to be manually uploaded through a system provided by the Tax Agency.
  • Electronically: Through the implementation of a web service that will require an XML file to be submitted. This system would allow companies to automate the declaration of movements each time a change in the inventory is recorded, and the data structure would be generated in accordance with the classification system defined by the Tax Agency.

What time limit will companies have to report movements?

Accounting entries must, by default, be submitted to the Tax Agency within 24 hours of the movement.

In practice, this time limit can be extended to four days, since Article 6, Paragraph 3 of the regulation provides for a period of 96 hours for all companies that record movements, operations, processes, and inventory through a computerized accounting system.

What information are companies required to declare?

Companies must report accounting entries, as well as cancellations when said entries need to be modified for any reason.

The communication of these entries will be based on specific characteristics related to the data structure and communication service with the Tax Agency, which depend on the establishment type to which the company is assigned:

  • Alcohol and Alcoholic Drinks
  • Hydrocarbons
  • Tobacco Products
  • Mixed (Alcohol and Tobacco Products)

The Tax Agency will provide a system that allows each of these groups to view information on their movements and stock through the same channels used for communicating said information.

How do I prepare my company for SILICIE?

The launch of SILICIE may require companies’ management systems to be modified, especially in the case of companies with a high volume of movements of products subject to excise duties.

The requirement to report a movement within a maximum period of four days will require, as a minimum, the development of procedures designed, in the first instance, to generate this information in the manner and within the timescale required by the Tax Agency. It will also require mechanisms and technology to be adopted to open communications with the Tax Agency within the agreed period with a view to reporting accounting entries within the defined 96-hour limit.

EDICOM, as a developer of data integration solutions, can help you launch your communications project to prepare for the Immediate Disclosure of Excise Duties Account Books. Our platform transforms the data generated by your management systems to the standard required by the Tax Agency every time you need to report an entry. We then establish communication with the Tax Agency, depending on the group to which your company belongs, thus automating the communication of this information.

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