On April 5, 2023, the Royal Decree 249/2023 was published in the Official State Gazette, introducing substantial changes for all stakeholders in the alcoholic beverages industry, including our company, Affinity Drinks. This change entails the creation of the Registry of Extractors from Fiscal Depositories (REDEF), which directly impacts how we manage the taxation of our products.
Who Needs to Register in the REDEF and Why Is It Important for Us?
Registration in the REDEF is mandatory for wholesale operators and other authorized agents who carry out extractions from fiscal depositories of products subject to Taxes on Alcohol and Derived Beverages. Since Affinity Drinks handles a considerable portion of these products, it is crucial for us to ensure that all related processes are fully compliant with this new regulation.
Impact of the REDEF
Registering in this registry is not only a legal requirement but also enables us to strengthen our internal processes against VAT fraud. By being registered, we have access to more rigorous control and state supervision that ensures transparency and legality in all our extraction operations.
Objectives of the Law
After several months of operation, the Registry of Extractors from Fiscal Depositories (REDEF) has proven to be an effective tool in preventing VAT fraud in the alcohol and hydrocarbons sector.
The REDEF allows for the creation of a manageable and supervisable census, providing early information to combat organized and complex fraud in these sectors, thus strengthening companies that operate ethically.
In the commercialization chain of these products, the extractor plays a crucial role in managing VAT, being the transition point between exempt and taxed operations. Since the extractor purchases without VAT and sells with VAT, they are responsible for the substantial input of an important part of the final tax that the product will bear at all its stages, and this is leveraged to lower prices, omitting the input of this VAT.
Benefits of Complying with the REDEF
Complying with the REDEF not only avoids significant penalties but also offers strategic advantages such as:
- Fraud Prevention: Being registered in the REDEF allows us to take proactive measures against VAT fraud, a prevalent problem in the industry.
- Supply Chain Transparency: As a crucial point in the commercialization chain, we ensure that all operations from purchase to final sale are transparent and properly documented.
- Enhancement of Corporate Reputation: Complying with fiscal regulations is not only good for avoiding penalties but also strengthens our reputation as a responsible and ethical company.
When Is Registration Not Necessary?
It is also vital to understand when registration in the REDEF is not necessary, which applies to VAT-exempt operations and entities that do not perform direct extractions, such as transporters and end buyers.
Resources and More Information
For those interested in exploring more about this decree and its applicability, we recommend reviewing the official document in the BOE, and of course, we are available to answer any questions or provide more specific details about our operations.
To be included in this Registry, both the extractor and any authorized person to perform extractions must submit an application using form 036. It is necessary to specify in the application the type of product related to the extraction.
Registration in the Registry of extractors is of public nature and is available for consultation by holders of fiscal deposits or any interested person at any time via electronic means. The Tax Administration will provide the necessary technical systems to access and verify the status of registered operators.
You will need to provide specific details of the types of products you extract and any other documentation that supports your operation and compliance with current tax regulations. It is recommended to consult with a tax advisor to ensure that all necessary documentation is complete.
You can verify your registration status through the electronic headquarters of the Tax Agency using an electronic certificate. It is crucial to perform regular checks to ensure that your registration status is up to date and in compliance with the law.
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