SILICIE - Immediate Disclosure of Excise Duties Account Books

A new system called SILICIE (Immediate Disclosure of Excise Duties Account Books) has been defined by Royal Decree 1512/2018 of December 28, which will come into effect on the January 1, 2020, for Companies affected by regulations governing Excise Duties (alcohol, tobacco and hydrocarbons), whereby said companies will have to declare both the stocks of products and the raw materials used in them.

Which companies are required to comply with SILICIE?

All companies that store, transport, manufacture or sell products subject to Excise Duties, this includes:

- Factories

- Tax warehouses

- Tax stores

- Receiving warehouses

- Vinegar factories

What is the scope of the change?

Companies will have to communicate via the Tax Agency's (AEAT) E-Office the processes, movements and stocks of the products subject to Excise Duties and, where appropriate, of the raw materials necessary to obtain them, including any differences that may arise in storage, manufacturing or circulation processes.

Are there any changes with respect to the presentation of current forms?

The fulfilment of this obligation will generally exempt one from presenting Form 570 Declaration of Operations regarding hydrocarbons.

For manufacturers of products with or derived from alcohol, the obligation to present Forms 553 and 548, which will be calculated internally, will disappear.

What kind of movements do I have to report?

The Tax Agency's services will allow the operation of registration of an accounting entry, as well as its eventual cancellation.

The types of possible entries are specified within an accounting entry movement.

The AEAT will also provide the possibility of consulting the entries and inventory balances calculated by each establishment from the opening entry and the subsequent movements.

What deadlines do I have for the presentation of operations?

Operation                                                             Deadline

Manufacturing costs accounting                     5 days after end of month 

Input / output operations                              As soon as it occurs

Once registered in the company accounting system, there are 4 days to send it to the Tax Agency, as long as said movement is reflected in the accounting.

What are the options for transmitting the data?

The data can be transmitted via WEB form, Text file or through Web service.

The companies or third parties that act as representatives of the subjects obliged to provide this information may disclose SILICIE accounting entries through a Web form found on the Tax Agency's E-Office. They must do it by sending a text file or, more automatically, through a web service system.

The web service will receive an unsigned XML format message. It will be possible to send multiple entries for each Web service call sent. Each file sent can contain up to 1000 entries per call.

The information to be supplied will be different depending on the type of product declared:

•            Alcohol and Alcoholic Beverages. Grouping:

-             Tax on beer.

-             Tax on wine and fermented drinks.

•            Tax on tobacco products:

-             Establishments that store and market products affected by taxes on Alcoholic Beverages and tobacco products

•            Hydrocarbons Tax.

Has a transition period been defined?

At the beginning of the obligatory period, establishments must send opening entries which will register the stocks of products at that time.  From these first entries on, all movement of materials for the same establishment must be communicated.

Cancellations of accounting entries prior to January 1, 2020 should not be communicated. Only those movements registered from January 1, 2020 on, will be considered valid.

From when will I be able to test the SILICIE system?

The current defined calendar to start testing is follows:

  • 01/06/2019 – Tax Agency test environment available.
  • 15/09/2019 – Opening of the A Tax Agency production environment for testing (can be conducted until 15/12/2019)
  • 01/01/2020 – Start up of SILICIE.

What other obligations must the required companies fulfil?

The Decree Law requires accounting books, as well as the transmitted files, to be stored in a computerised format for a possible inspection by Treasury technicians.

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