Bizkaia: What is Batuz LROE?

Kelly Muniz
May 31, 2023

The Ledger of Economic Operations (Libro Registro de Operaciones Económicas), also known as LROE, is a main compliance element of the Batuz tax control system. This system is under implementation in the province of Bizkaia, located in the autonomous Basque community in Spain.

Taxpayers under the Batuz mandate must comply with both TicketBAI and LROE obligations. While TicketBAI applies to invoice issuance, LROE rules require taxpayers to electronically record and report data on income, expenses and other fiscally relevant information to the tax authority in a structured format.

Regardless of size or business volume, individuals engaged in economic activities and organizations must meet LROE requirements if subject to Bizkaia regulations on Personal Income Tax, Corporate Tax or Non-Resident Income Tax for permanent establishments. The rule will come into effect on 1 January 2024 and includes taxpayers currently subject to Bizkaia’s SII (Immediate Supply of Information) mandate.

What is LROE reporting?

LROE is the electronic ledger where taxpayers must document several economic activities and report such financial information to the tax authority. Individuals engaged in economic activities report this information via model 140, while companies use model 240.

For compliance with LROE, taxpayers must record and transmit their sales, purchases and other financial data in a structured XML format according to legal technical specifications. Taxpayers can send the data in the ledger either through webservices or manually uploaded via the portal provided by the Bizkaia Tax Authority.

The LROE structure

The structure of LROE information for companies and non-resident taxpayers with permanent establishment (model 240) is comprised of the following:

  1. Chapter of invoices issued
  2. Chapter of invoices received
  3. Chapter of investment goods
  4. Chapter of certain intracommunity operations
  5. Chapter of other information with tax significance
  6. Chapter of accounting movements

Certain chapters also contain subchapters. The chapter of issued invoices, for example, has a subchapter of issued invoices with guarantor software which requires transmitting data from invoices generated using TicketBAI.

In the case of Bizkaia, as taxpayers do not need to submit the TicketBAI XML (generated with the invoice) directly to the tax authority, they will send this data via the LROE subchapter in a specific TicketBAI field.

Batuz LROE submission deadlines

The deadline to submit the LROE files to the tax authority varies according to the type of taxpayer under the obligation.

The general deadline is quarterly. Taxpayers must report the data from when the transaction is carried out until 25 April, 25 July, 25 October, or 25 January – depending on the specific quarter.

The deadline for companies under the Bizkaia SII obligation to submit LROE records is four days from the operation’s completion, in line with the general SII deadline. The SII obligation will be considered fulfilled by submission of the LROE.

Penalties for non-compliance

Failure to comply with the requirement to keep and submit LROE records electronically will result in a monetary fine. The proportionally calculated penalty is 0.5 percent of the transaction amount the taxpayer failed to report, with a quarterly minimum of 600 EUR and a maximum of 12,000 EUR.

What’s next for compliant taxpayers?

By using the TicketBAI invoicing system and reporting the LROE, taxpayers will provide information to the tax authority so that it can fulfil the third element of the Batuz tax control system.

The third element of Batuz entails the preparation of pre-filled VAT draft returns and Corporate and Personal Income declarations, which will be available for taxpayers in Bizkaia from 2024 forward.

Need more information about Batuz LROE or tax in Bizkaia? Contact our team of experts today.

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Kelly Muniz

Kelly Muniz is a Junior Regulatory Counsel at Sovos. Based in Stockholm and originally from Brazil, Kelly earned a Bachelor’s degree in Law in her home country, where she worked as a licensed lawyer. She also holds a Master’s degree in EU Business Law from Lund University in Sweden.
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