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 January 1, 2020.
Contents
SILICIE: What is it?
Aimed at companies affected by the regulations governing Excise Taxes (alcohol, tobacco, and hydrocarbons), which require these companies to declare both their product inventories 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.
- Bonded warehouses.
- Receiving tanks.
- Bonded warehouses.
- Vinegar factories.
Integration of SILICIE and its relevance in excise taxes
The correct integration of SILICIE into companies' accounting processes is key to ensuring regulatory compliance and avoiding penalties. This system allows for more efficient and transparent control of operations related to products subject to excise duties, streamlining data transmission and improving traceability. Adapting to this mechanism not only facilitates administrative work, but also optimizes the internal management of obligations related to SILICIE and excise duties.
SILICIE: What does it imply?
What is the scope of the change?
Companies will have to communicate via the Electronic Headquarters of the Tax Agency the processes, movements, and stocks of products subject to Special Taxes and, where applicable, the raw materials necessary to obtain them, including any differences that may arise in the storage, manufacturing, or circulation processes.
Are there any changes with respect to the presentation of the current models?
Compliance with this obligation will generally exempt you from filing Form 570, Declaration of Operations regarding hydrocarbons.
Manufacturers of products containing or derived from alcohol will no longer be required to submit forms 553 and 548, which will be calculated internally.
What kind of movements do I have to report?
The services of the AEAT will allow the 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 are the deadlines for submitting transactions?
The deadlines for accounting registration in the financial system are described below:
| Operation | Deadline |
| Transformation accounting | 5 days after the end of the month |
| Entry/exit operations | At the moment 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 options do I have for transmitting the data?
The data can be transmitted via WEB form, Text file or through Web service.
Companies or third parties acting as representatives of those required to provide this information may supply the accounting entries of SILICIE using a web form available on the AEAT website. They must do so 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. Groups:
- Beer tax.
- Tax on wine and fermented beverages.
- Tax on Tobacco Products:
- Establishments that store and sell products subject to excise taxes on alcoholic beverages and tobacco products.
- Tax on hydrocarbons.
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.
When will I be able to try out 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.
