RTC Suite is a Cloud platform to meet the requirements of e-Invoicing in Spain and other countries, as well as e-Reporting, Periodic Reporting and SAF-T.
La Ley Crea y Crece: Transforming the Tax and Billing Landscape
The Crea y Crece Law will bring about a significant transformation in the tax and invoicing landscape, with the introduction of mandatory electronic invoicing (e-invoicing). This change is based on two key pieces:
- Law 25/2013: establishes the obligation of electronic invoicing and the creation of the entry registration point, requiring the use of electronic invoicing in Business-to-Government (B2G) transactions since 2015.
- Law 18/2022 (Crea y Crece): Introduces mandatory Business-to-Business (B2B) electronic invoicing. This law will require all B2B transactions to be made exclusively with electronic invoices once it comes into force.
These laws aim to improve efficiency, reduce tax evasion and modernize Spain’ s economic infrastructure. However, they also present challenges and considerations for companies that must adapt to comply with the new regulations.
Scope and implementation schedule
B2G transactions
Mandatory electronic invoicing has been in force since 2015 under Law 25/2013, which requires suppliers to public administrations to submit electronic invoices.
B2B transactions
Law 18/2022 will extend mandatory e-invoicing to B2B transactions. The current state of Crea y Crece has been approved by the EU Commission.
- Large companies (revenues > €8 million): They are expected to be compliant one year after the publication of the technical regulations, making it 2026 at the earliest.
- Small and medium-sized enterprises (SMEs): Expected to comply two years after publication, making it 2027 at the earliest.
Key considerations
Compliance obligations
The new mandate introduces additional compliance obligations beyond the existing Immediate Supply of Information (SII) system. E-invoicing will require real-time issuance and remittance of invoices, rather than near real-time reporting under the SII.
Technical requirements
Companies must adapt to standardized electronic invoice formats such as Facturae, UBL, EDIFACT and CII. They must also implement advanced electronic signatures and comply with specific communication protocols (SOAP, WSDL).
Operational impact
The move to mandatory electronic invoicing can significantly impact business processes, especially order-to-cash cycles. Errors in electronic invoicing can disrupt operations and affect relationships with trading partners.
Data reconciliation
Ensuring consistency between e-invoicing data, VAT returns and SII reports is crucial. The tax authorities will perform a double-check.
Flexibility in invoice formats
Direct interaction with tax authorities limits companies to certain electronic invoicing formats, which could make it difficult to do business with partners using different formats.
Differences with IBS
The new electronic invoicing mandate differs significantly from the existing SII system:
Real time vs. near real time
Electronic invoicing requires the immediate issuance and sending of invoices, while the SII allows for a certain delay in the notification of VAT data.
Operational impact
Under SII, errors can often be corrected before and after submission without seriously affecting business operations. With mandatory electronic invoicing, inaccuracies at the time of issuance can disrupt invoicing processes and affect relationships with business partners.
Data requirements
Electronic invoicing introduces additional data elements, such as invoice status, and other technical specifications not required under the SII, which increases the complexity of compliance.
Additional aspects to consider
In addition to everything related to business and billing processes, companies should consider the following points as they move forward on their e-invoicing journey:
VAT reconciliation and compliance
Ensure that e-invoicing data is aligned with VAT returns and SII reports. Any discrepancies between e-invoicing data and VAT returns could result in requirements or queries from tax authorities. Accurate real-time data submission minimizes compliance risks and supports efficient tax filing.
Managing changes while continuing business operations
Implementing any e-invoicing solution while maintaining regular business activities requires advanced planning:
- Minimize disruption: Selecting solutions that integrate seamlessly with existing systems reduces operational downtime.
- Resource allocation: Proper planning and resource allocation ensures that compliance efforts do not detract from core business functions.
Adaptation of employees and business partners
Training and support help employees adapt to new processes without significant loss of productivity.
Impact on companies
Option 1: Internal implementation management
Companies may consider managing electronic invoicing internally by integrating their systems directly with the tax authorities. However, this approach presents several challenges:
- Limited flexibility in formats and communication: Direct integration restricts companies to the Facturae format and limited communication methods.
- Technical complexity and resource demands: IT teams will need to develop and maintain systems that meet technical specifications, including digital signatures, XML schemas and secure communication protocols.
- Ongoing maintenance and upgrades: Maintaining compliance with evolving regulations requires constant system upgrades and monitoring, which increases pressure on internal resources.
This is the case when choosing to implement a solution based on the SAP standard, where there are mainly two implementation options at the infrastructure level:
- Use the standard SAP infrastructure, either PI/PO, Integration Suite or DRC.
- Have an external supplier provide the connector between our SAP system and the authorities.
Both options must be connected to the SAP e-Document solution, which would perform the functions of a Central Cockpit.
Option 2: Partnership with a Certified Electronic Service Provider (ESF) as a RTC
Collaborating with a certified electronic service provider (ESF) offers several advantages:
- Flexibility in invoice formats: Allows sending and receiving invoices in various formats-Invoiceurae, UBL, EDIFACT, CII-ensuringsmooth transactions with customers and suppliers.
- Enhanced communication methods: ESFs provide advanced communication channels beyond those provided by direct interfaces with tax authorities.
- Expertise and compliance assurance: ESFs specialize in e-invoicing regulations and technical requirements. They keep up to date with legislative changes.
- Technical support and maintenance: Providers take care of system maintenance, upgrades and technical issues, reducing the operational burden on the company.
- Integration with existing systems: ESFs offer solutions that integrate with existing ERP systems, minimizing disruption and ensuring a smoother transition to electronic invoicing.