The Ministry of Economic Affairs and Digital Transformation, together with the Ministry of Finance and Public Function, has published today, on March 7, 2023, the public consultation document on the regulatory development of the B2B electronic invoice.
The objective of this consultation is to gather the opinions of individuals, providers, and relevant organizations on the technical details of the implementation of the B2B electronic invoice in Spain, in preparation for the final text.
The document details the context and objectives of the electronic invoicing legislation, the main elements planned in its regulatory development, and finally, 22 open questions are posed to gather the opinions of interested parties.
The deadline for sending observations and comments will be until March 22, 2023.
On September 29, 2022, the Spanish Government published the Crea y Crece Law, introducing the obligation to use electronic invoicing for B2B relationships in Spain.
This Law contemplates a period of 6 months from its publication for the Ministry to indicate the technical details of the implementation of this model of electronic invoicing.
The 6 months marked by the government would be fulfilled during the month of March 2023; therefore, we can expect that the development will be delayed to some extent. However, the publication of this public consultation represents a first step towards the publication of the Royal Decree with the regulatory development of the B2B electronic invoice, which will undoubtedly arrive during 2023.
Finally, judging by the elements planned in the development, the Ministry seems inclined to propose a system similar to the French one, based on the interoperability of a network of electronic invoice exchange platforms, complemented by a public system of basic electronic invoice exchange.
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