- Objective of the Decree: The draft Royal Decree aims to establish a Spanish electronic invoicing system to facilitate business growth by combating late payments and promoting digitalization among small and medium-sized enterprises and self-employed professionals.
- Public Hearing Update: This is the second public hearing for the draft, reflecting recent developments and amendments that necessitate further modifications, including clarifications on invoicing standards and obligations for electronic invoice submissions.
- Key Provisions: The draft includes updates on invoice definitions, obligations for platforms to submit invoices to a public e-invoicing solution, and aligns with upcoming changes in European VAT regulations, with a proposed implementation timeline of one year after the Ministerial Order approval.
These are the articles and provisions that are submitted to the public hearing and the reasons for the proposed modifications
- Article 1: it now reflects that this Royal Decree also develops the new additional provision 21 of Law 56/2007.
- Article 2(e): a clearer definition of a true copy to be submitted to the public e-invoicing solution is introduced when invoices are exchanged using private e-invoice exchange platforms.
- Article 4: eliminates the exception to issue electronic invoices for invoices that are issued voluntarily without there being an obligation to do so according to the Regulation regulating invoicing obligations, approved by Royal Decree 1619/2012, of 30 November.
- Article 6.2: clarifies, as already established in Law 56/2007, that it will be the platforms, solutions or invoicing systems used by issuers of electronic invoices that will be obliged to send the true copy to the public e-invoicing solution and that this must be done in the UBL format.
- Article 10.5: Clarifies issues regarding payment information when using debits and credits.
- Article 11.2: alters the syntax to be used by the public e-invoicing solution, which becomes UBL (Universal Business Language), thus aligning itself with both the European standard EN16931 and the imminent amendment of Council Directive 2006/112/EC, of 28 November 2006, on the common system of value added tax.
- Article 15: clarifies the method of calculating the term of payment of invoices, stating the start and end date of said period.
- Additional provision 1: clarifies that invoices issued using the electronic invoice generation web form of the public electronic invoicing solution will also be of the VERIFICACTU modality, i.e. verifiable in accordance with Article 6, paragraph 5, letter b) of the Regulation governing invoicing obligations, approved by Royal Decree 1619/2012, of 30 November.
- Additional provision 3: the wording related to the regional treasuries and the AEAT is revised.
- Transitional provision 2 and 3 and final provision 4: clarifies that the entry into force will take place one year after the approval of the Ministerial Order that will develop the public e-invoicing solution (and which culminates the regulatory development of Law 18/2022) and will maintain, as of that date, the start of staggered effects already foreseen for smaller companies and for the self-employed and other professionals.
Source
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE