FAQs

Establishments affected by the regulations governing Special Taxes must keep records of the products subject to said taxes and, where applicable, the raw materials necessary to obtain them, in accordance with the terms established in article 50 of the Regulations on Special Taxes and its implementing regulations.

Accounting must reflect the processes, movements, and existence of products subject to Excise Duties, and where relevant the raw materials used to produce them, including any differences that arise during their storage, manufacture, and/or circulation.

The accounting of products subject to Special Taxes must reflect a true and fair view of the physical reality of the quantities of products subject to Special Taxes and, where applicable, raw materials in the establishment.

The SILICIE system applies from 1 January 2020.　

As a general rule, the owners of establishments required to keep accounting records through the electronic headquarters of the State Tax Administration Agency must provide the accounting entries corresponding to the movements, operations and processes carried out from January 1, 2020.

The owners of the following types of establishments will be required to keep accounts for Special Taxes through the electronic headquarters of the Tax Agency:

• Factories

• Tax warehouses

• Bonded warehouses

• Receiving depots

• Vinegar factories

Yes. In general, wine producers (wineries) have the status of factories for the purposes of Special Taxes, and are required to keep accounts through the electronic headquarters of the Tax Agency.

However, wine producers whose annual production volume (including that of all the establishments they own) does not exceed 100,000 litres may be authorised, upon request, by the Management Office to keep accounts for Special Taxes using foliated books on paper.

In general, distillers have the status of factories, for the purposes of excise taxes, and are obliged to keep accounts through the Tax Agency's e-Office.

However, artisanal distillers may be authorized, upon request, by the Management Office, to keep the accounts of Special Taxes using foliated books on paper.

The accounting records must reflect all processes, movements and stocks of the products subject to Special Taxes and, where applicable, the raw materials necessary to obtain them, including any differences that may arise during storage, manufacturing or circulation.

Excise Duties accounts can be kept through the Tax Agency’s e-Office in two ways:

1. By electronically supplying the accounting entries directly through said headquarters.
2. By electronically supplying accounting entries, from the computerized accounting system available, where applicable, to the obligated party.

The maintenance of accounting records and the provision of accounting entries from the taxpayer's internal accounting system on computer support requires the prior exercise of this option through the electronic headquarters of the Tax Agency, using the form provided for this purpose.

You need not submit the receipt document for entries provided to the Tax Agency when submitting them via the Tax Agency’s e-Office.

The supporting documentation and information relating to the movements, products, stocks, processes and operations subject to electronic supply must be available to the inspection services and, where appropriate, to the intervention services, in the establishment itself, as long as the limitation period for the Administration's right to determine the tax debt through the appropriate settlement has not expired.

A new version of the SILICIE system will be applicable starting January 1, 2025. This system is based on accounting by fiscal year, and the provision of accounting entries is linked to the fiscal year in which the transaction, operation, or process occurs.

The main new features introduced from January 1, 2025, are as follows:

1. The accounting year is defined, which coincides with the calendar year.

2. The obligation to report the opening and closing of each fiscal year through the Tax Agency's electronic office is established.

3. Accounting entries may only be provided for financial years for which the closing has not been reported. Once the closing of a financial year has been communicated, it is not possible to cancel or provide accounting entries attributable to that year.

4. Criteria are established to correctly identify products.

The SILICIE system is available in two versions:

• SILICIE Version 1.0: applicable from 1/1/2020 to 31/12/2024. This version will present entries for the years 2020 to 2024.

• SILICIE Version 2.0: applicable from 1/1/2025. This version will present entries corresponding to transactions, operations, or processes carried out as of January 1, 2025, adapted to the modifications and specifications introduced by Order HAC/1505/2024, of December 26.

Regarding the Beer Tax, it will not be necessary to reflect in the accounting records the movements and stocks of raw materials incorporated into the production process that are not subject to Special Manufacturing Taxes and do not contain extracts.

Regarding the Tax on Alcohol and Derived Beverages, in operations related to the manufacture of derived beverages, it will not be necessary to reflect in the accounting records the movements and stocks of raw materials that do not have an alcoholic content and do not contribute alcohol content or volume to the resulting beverage.

As a general rule, the opening entry must be submitted within the first month of the financial year.

Notwithstanding the foregoing, owners of establishments that can apply special extended deadlines for submitting their accounting entries may consider the opening entry to correspond to a transaction in the first month of the fiscal year and submit it within the deadline provided for entries for that month. This rule may be applied:

• The owners of establishments authorized as wine producers and producers of other fermented beverages referred to in the First Additional Provision of Order HAC/998/2019.

• The owners of establishments authorized as breweries referred to in the Second Additional Provision of Order HAC/998/2019.

• The owners of establishments authorized as producers of intermediate products that do not obtain alcohol, as referred to in the Third Additional Provision of Order HAC/998/2019.

• The owners of establishments authorized as bonded warehouses consisting of a gas pipeline network or as natural gas and other gaseous product extraction industries referred to in the Fifth Additional Provision of Order HAC/998/2019.

• The owners of establishments authorized as producers of alcoholic beverages referred to in the Sixth Additional Provision of Order HAC/998/2019.