CUTFLOW

RESPONSIBLE DECLARATION OF THE INVOICING SOFTWARE SYSTEM

Status: VERSIONED DRAFT 0.10.12 — pending legal approval and publication
Manifest: cutflow-core/compliance/verifactu/fiscal-release-manifest.json
Version source: cutflow-rn/.version.properties (VERSION_NAME=0.10.12)
Legal basis: Article 15.1 of Order HAC/1177/2024.

Each descriptor below reproduces the minimum required content and the legally prescribed order. The version matches VERIFACTU_SYSTEM_VERSION and the application version.

1.a)

Name of the invoicing software system referred to in this responsible declaration. As a general rule, this shall be the generic name under which the system is distributed or marketed.

Cutflow.

1.b)

Identification code of the invoicing software system referred to in section 1.a), in accordance with the specifications set out in section 2.6 of the Annex. This code shall be established by the person or entity producing the invoicing software system and shall uniquely identify it in a concise manner, instead of using the longer name indicated in section 1.a). This code may not be the same as that of any other invoicing software system produced by the same person or entity.

01.

1.c)

Full identifier of the specific version of the invoicing software system referred to in this responsible declaration.

0.10.12.

1.d)

Hardware and software components that make up the invoicing software system referred to in this responsible declaration, together with a brief description of what the system does and its main functionalities.

Cutflow 0.10.12 is a multi-taxpayer SaaS system for business management, issuance of full and simplified invoices, printing, consultation, statistics, and data export.

It consists of:

• cutflow-core, which performs invoicing and maintains the fiscal record, chaining, and submission processes.
• cutflow-etax, which generates XML files and securely transmits them to the Spanish Tax Agency (AEAT).
• cutflow-ng, the web administration client.
• cutflow-rn, the terminal and printing application.
• cutflow-verifactu-dss, the service responsible for validation and countersigning of authorizations.

The system does not require specific fiscal hardware and is used from compatible devices and equipment connected to the service.

1.e)

Indication of whether the invoicing software system referred to in this responsible declaration has been produced in such a way that, for the purposes of complying with the Regulation, it can operate exclusively as “VERI*FACTU”, in accordance with the specifications set out in section 2.6 of the Annex.

Yes. The declared variant operates exclusively as VERI*FACTU. SII and non-Spanish markets are outside the scope of this declaration.

1.f)

Indication of whether the invoicing software system referred to in this responsible declaration may be used by several taxpayers or by a single user to support the invoicing of several taxpayers, in accordance with the specifications set out in section 2.6 of the Annex.

Yes. The SaaS architecture supports multiple taxpayers and maintains an independent fiscal chain for each taxpayer.

1.g)

Types of signature used to sign invoicing records and event records where the invoicing software system referred to in this responsible declaration is not used as “VERI*FACTU”.

Not applicable to the declared variant. It operates exclusively as VERIFACTU and does not use an explicit signature for records under the non-VERIFACTU mode.

1.h)

Full name of the person, or corporate name of the entity, producing the invoicing software system referred to in this responsible declaration.

Cutflow LLC.

1.i)

Spanish tax identification number (NIF) of the person or entity producing the invoicing software system referred to in this responsible declaration. If no Spanish NIF is available, another available identification number must be provided, indicating the type of identification and the country that issued it, in accordance with the specifications set out in section 2.6 of the Annex.

Foreign identification: EIN 38-4292742, type 04, issued by the United States (US).

1.j)

Full postal contact address of the person or entity producing the invoicing software system referred to in this responsible declaration.

1111B S Governors Ave, Suite 7314, Dover, Delaware 19904, United States.

1.k)

The person or entity producing the invoicing software system referred to in this responsible declaration shall state that the software system, in the version indicated herein, complies with the provisions of Article 29.2.j) of Law 58/2003, of 17 December, General Tax Law; the Regulation establishing the requirements to be adopted by computer or electronic systems and programs supporting invoicing processes of entrepreneurs and professionals, and the standardization of invoicing record formats, approved by Royal Decree 1007/2023, of 5 December; this Order; and the electronic headquarters of the Spanish State Tax Administration Agency for all matters supplementing the specifications of this Order.

Cutflow LLC hereby declares that the Cutflow invoicing software system, version 0.10.12, complies with the provisions of Article 29.2.j) of Law 58/2003, of 17 December, General Tax Law; the Regulation approved by Royal Decree 1007/2023, of 5 December; Order HAC/1177/2024, of 17 October; and the electronic headquarters of the Spanish State Tax Administration Agency for all matters supplementing the specifications of said Order.

1.l)

Date and place where the person or entity producing the invoicing software system signs this responsible declaration. The date must be complete and indicate the day, month, and year, in that order. The place must contain, at a minimum, the name of the locality and the country, in that order.

11 September 2026. Dover, United States.