Frequently asked questions (FAQ)

The regulations of this project do not detail how billing records can be stored. Various technical solutions are supported, provided that they meet the required functionalities (integrity, exportability, etc.). The aforementioned is a possibility that seems appropriate since it should entail less need for conversion.

When it is necessary to change any data in a billing record already produced, another record must be generated to complete, modify or cancel the content of the previous one, but the first billing record cannot be altered or manipulated to prevent the invoice sequence from being altered.

Therefore, no actions are allowed on billing records once they have been definitively produced.

To modify a “high billing record” a new cancellation record must be generated. In the latter case, it may be a complete cancellation of the initial registration or a correction/replacement (i.e. replacement of the “registration record” with another corrected record). In any case, the way to proceed is to create new cancellation/correction records and never directly alter the previously generated billing records.

In the event that the intention is to change invoice details that are not included in the “high billing record”, and which, consequently, do not determine an alteration in the high record produced, the correction will not require generating a new record, and can be done directly.

In the operations of the one-stop shop (OSS) regimes, contemplated in article 166.bis of the VAT Law, 37/1992, introduced by Royal Decree Law 7/2021, the regime code to be indicated from list L8 is "17": Operation covered by one of the regimes provided for in Chapter XI of Title IX ( OSS and IOSS ).

As for the invoice code to be reported from list L2, it will be the one that corresponds to the nature of the invoice, depending on whether it is an ordinary/complete invoice ("F1") or a simplified invoice ("F2").

In invoices there are perfectly valid voluntary mentions, which derive from commercial practices or even of another nature, and which, on the one hand, are not mandatory tax mentions of article 6.1 of the Regulation of Invoicing Obligations, approved by RD 1619/2012; and on the other hand, they have not been included as mentions in the billing record, which is regulated in article 10 of the RRSIF , which approves RD 1007/2023. As is known, the aforementioned registry is simplified. Therefore, the amounts supplied, as is the case with the financial surcharge, are not "own" amounts of the billing record, and do not have to be included among the mentions of the "high billing record". However, if they are included as a higher amount in the concept “Total invoice amount” (which is not mandatory), they must be recorded as an amount not subject to VAT or amounts at zero rate (0%).

As regards withholdings, these are not formally part of the billing record (they are not one of the constituent elements of the invoice according to the EU Directive).

Notwithstanding what is mentioned in the previous paragraphs regarding the high billing records, nothing prevents including these or other mentions in the invoice actually issued and printed (or sent electronically) to the recipient, which will contain all the logistical, financial, etc. information. that is accurate or convenient. However, the extract of mandatory information that is part of the “high billing record” (and which is detailed in article 10 of the RRSIF ) will not include such data.

Regarding early payment discounts, the administrative doctrine can be summarized as follows:

• The granting of discounts and bonuses is a common practice within the business environment as a method to encourage sales. The consequence of these, regardless of the accounting treatment used, is a reduction in the purchase price of the corresponding goods or services.

• These discounts and bonuses may be granted in cash or in kind. Generally, these are discounts for early payment , promotional discounts (seasonal or seasonal, start of a new activity, liquidation, introduction of a new product, due to the status of the purchaser, etc.), quantity discounts related to a transaction and others with similar characteristics.

• Discounts or bonuses are not part of the tax base when the following requirements are met:

  1. That they are justified by any means of evidence admissible in law. Generally, the document that justifies its practice is the invoice itself that documents the operation, without it being necessary for such discounts and bonuses to appear separately, although their existence must be proven, a circumstance particularly relevant in related-party transactions. However, it is required that the invoice contain all the data necessary for determining the tax base , making express mention, where appropriate, of any discount or reduction that is not included in the unit price, a concept that must always appear on the invoice.

  2. That they are granted prior to or simultaneously with the time of carrying out the operation - the time of accrual of the tax. This is the commercial practice for this type of discounts, with those granted at the time of the transaction predominating. When discounts or bonuses are granted after the transaction is carried out, they also affect the tax base, modifying its amount downwards.

  3. That they are granted based on such operation.

  4. That they are not remuneration of other operations carried out by the recipient of the operation or by a third party on his behalf, in favor of the taxpayer who carries out the operation to which the granting of discounts or bonuses is intended to affect.

In accordance with the above, the invoice must include the discount for prompt payment when it is granted prior to or simultaneously with the transaction.

Since this is the high registration prior to the invoice and from which the invoice will be generated, if you want a record of said discount to be kept, it must appear in the “high billing register”. The way to include it is in one of the lines of the breakdown block, without prejudice to mentioning the discount in the “description of the operation” field.