Supply obligation for 2020

The obligation to keep the accounts of products subject to Excise Duties through the online site of the Tax Agency, by means of the electronic supply of accounting entries came into force on 1 January 2020.

Consequently, if you are the owner of a SILICIE-registered establishment, you must provide for all accounting entries corresponding to movements, operations or processes carried out as of 1 January 2020.

However, in order to facilitate the implementation of the system, the regulations include a transitional regime, whereby the provision of accounting entries for the year 2020 may be made within longer periods than those generally envisaged:

1. If you have not benefited from the transitional period provided for in the first Transitional Provision of Order HAC/998/2019, of 23 September, you must have supplied the accounting entries electronically from 1 January 2020 within the deadlines that correspond to the supply method applicable to your establishment:

   • If you provide your entries directly at the Tax Agency's electronic office, within 24 hours of the date of the movement, operation or process.
   • If you have opted for the supply of your entries in the Tax Agency's electronic office from your accounting system in computerised format, within the period of 8 working days (5 working days from 1 January 2021) following the date of registration in your accounting system or the end of the deadline for registration if this has not been done within the deadline.
   • You will not be obliged to file the declaration of transactions provided for in Article 44.5 of the Excise Duty Regulation with effect from 1 January 2020.
2. If you have made use of the transitional period provided for in the first transitional provision of Order HAC/998/2019, of 23 September:
   • You will be able to provide through the Tax Agency's electronic headquarters the accounting entries corresponding to the movements, operations and processes carried out since 1 January 2020 in the period between 1 June 2020 and 15 January 2021.

• You must continue to comply with the accounting obligations in force in 2019 and submit the declarations of transactions corresponding to all settlement periods (monthly or quarterly) until 31 December 2020, or until the end of the settlement period in which you keep your accounts in full through the electronic headquarters of the State Tax Administration Agency (Agencia Estatal de Administración Tributaria).

  For these purposes, it will be understood that you have fully kept your accounts through the electronic headquarters of the State Tax Administration Agency when you have provided all the accounting entries corresponding to the movements, operations and processes carried out since 1 January 2020.

• From the date on which you have fully implemented the electronic supply, and you keep your Excise Tax accounts entirely through the Tax Agency's electronic headquarters, you must supply the entries corresponding to the movements, operations or processes carried out within the deadlines set out in Order HAC/998/2019, taking into account the supply method applicable to your establishment.

  • If you file directly on the Tax Agency's online site, within 24 hours of the date of the movement, operation or process.

  • If you have opted for the supply of your entries in the Tax Agency's online site from your accounting system in computerised format, within 8 working days (5 working days as of 1 January 2021) following the date of registration in your accounting system or at the end of the deadline for registration if this has not been done within the deadline.