In September 2022, the Spanish government published the ‘Crea y Crece’ law, thereby taking its first steps towards a B2B electronic invoicing requirement. As it is presented now, ‘Crea y Crece’ will coexist alongside the SII principle, according to which Spanish companies have been reporting VAT-related information to their government since 2017. In what follows, we will briefly report on what is currently known about the new ‘Crea y Crece’ requirements, and what SAP will offer in order to comply with them.
The new Spanish B2B requirements
Pioneer within Europe, Spain entered the previously mostly Latin American realm of eDocuments in 2017, through the introduction of the ‘Suministro Inmediato de Información del IVA’ (SII) principle. SII is a system of near real-time B2G electronic reporting, ruling all VAT-related information from B2B transactions to be sent electronically to the Spanish tax authorities (‘Agencia Estatal de Administración Tributaria’ or AEAT). Its main purpose is to be an instrument in Spain’s fight against tax evasion. Aside from added control for the Spanish government, SII nonetheless also aims at helping Spanish companies to obtain their data for VAT returns more swiftly and precisely, and speeding up any refund process. More information on SII and SAP’s solution for the SII requirements, can be found in our previous blogpost: SII Spain: Reporting on VAT info with SAP Document Compliance
September 2022 subsequently saw Spain shifting its digitalization process into a higher gear. With the ‘Crea y Crece’ (Business Creation and Growth) law, the Spanish authorities dictate the use of electronic invoices in all transactions by companies and freelancers. Aside from accelerating Spain’s digitalization process, the new law equally aims at increased transparency for both government and businesses; and the promotion of growth through the evasion of late payments and unnecessary transaction costs. Contrarily to SII, which solely applied to certain types of companies (large companies, members of VAT groups or the REDEME scheme), ‘Crea y Crece’ targets all Spanish companies and freelancers. It will nonetheless be introduced in stages, starting out with large taxpayers (annual turnover of over 8 million euros) in 2025, before fanning out to the general public (expected in 2026). Furthermore, whereas SII presents its targeted document types in the form of ‘Books’ (e.g. ‘LFRE’ book of outgoing invoices, ‘LRFR’ book of incoming invoices), transactions affected by the new eInvoicing requirements will firstly be all B2B invoices, but in certain contexts also B2C invoices (i.e. in case of particular services, such as electronic and financial services, and with the explicit consent of the customer).
More detailed information on what exactly will be imposed by ‘Crea y Crece’ in the long term, is not yet provided at this point in time. In essence, it comes down to the fact that all Spanish companies with a fixed establishment from mid-2024 will need to be able to issue, receive and follow-up on electronic invoices. It is still unclear whether non-established businesses registered for VAT in Spain will be obligated to comply with the eInvoicing requirement as well. First sources nevertheless mention the mandatory incorporation of a QR code in the eInvoice, and an archiving requirement for at least three years.
Any future updates on the legal requirements will be added to this blogpost upon their release.
What SAP solution can be expected?
SAP has already announced a first solution, for SAP Business One systems, to be released in February 2024. For the remaining on-premise systems, the most recently communicated solution status from SAP is still ‘In Analysis’. It could nonetheless be expected that, similarly to its solution for SII Spain, SAP will make use of Document & Reporting Compliance for the country’s B2B eInvoicing requirement. SAP Document & Reporting Compliance is an overall, integrated SAP solution which strives for long-term end-to-end compliance with various country-specific legal requirements all over the world (e.g. SII Spain, SDI Italy, CFDI Mexico, RTIR and EKAER Hungary). With SAP Document & Reporting Compliance and the SAP eDocument Cockpit, the files required by the government will automatically be generated from source information in your system. From the eDocument Cockpit, you can easily submit the eInvoices to the government and customer, and keep track of their status.
This blog post will be updated as soon as more information becomes available on SAP’s planned solution.
Web-Meeting Legal Requirements Spain
Do you have further questions on the legal requirements for Spain or do you want to get a demo about compliance with the SII rules in SAP Document Compliance? Contact us!
How PIKON can help you
With our Competence Center for Legal Requirements, we are a strategic partner who ensures that your SAP system and business processes meet different country-specific legal requirements all over the world in the long run. We have a team of experts that combine SAP expertise and in-depth knowledge of the end-to-end legal process and technical requirements of the Spanish and many other eInvoicing and eAccounting regulations. We have gathered this experience through our many SAP Document & Reporting Compliance and local implementation projects all around the world. Some examples are SDI in Italy, SII in Spain, CFDI and Complemento de Pago in Mexico, RTIR and EKAER in Hungary, XRechnung in Germany, the different legal requirements in Turkey, etc. We have also developed our own compliance SAP Add-Ons e.g. MTD VAT in the UK and the VAT Whitelist in Poland. Furthermore, we always keep an eye on new and changing legal requirements and inform our customers when action is needed. This ensures that your company doesn’t need to follow up on all the legal requirements yourselves, and you can concentrate on your daily business.