The Spanish government has mandated e-Invoicing in B2G transactions since 2015. With the law “Crea y Crece” B2B electronic invoicing is also approved. Scope of the new regulation covers all Spanish VAT payer companies and individuals in generating and receiving electronic invoices. The mandate will be effective from July 2024 for large taxpayers with an annual turnover of more than €8 million and the implementation of e-Invoices will continue to continue to 2026. Threshold will decrease gradually and scope will cover all other taxpayers by time.
Five Key Questions About e-Invoicing in Spain
The Spanish Ministry of Finance has introduced a VAT data reporting system named the Immediate Supply of Information (Suministro Inmediato de Información–SII). SII is an example of European invoice reporting, alongside Hungary’s RTIR, and Greece’s myDATA. Invoice reporting means all billing data is sent to the tax authority’s (Agencia tributaria or AEAT) system in real-time electronically.
With the new law “Crea y Crece”, B2B electronic invoicing in Spain was introduced. Issuing and receiving electronic invoices will be mandatory for all Spanish VAT-paying companies and individuals. The obligation will begin in July 2024 for large taxpayers with a turnover above €8 million. The implementation process will continue until 2026 and cover all other taxpayers, even small and micro businesses.
We have gathered the top-five critical questions from our clients.
- If E-Invoicing becomes mandatory in Spain, will we use invoice reporting too?
Through the Suministro Inmediato de Información (SII), the Spanish Tax Authority (AEAT) already receives transactional information from certain taxpayers up to four working days after the issuing or receipt of an invoice. On the other hand, the switch to mandatory e-invoicing would mean that a larger group of taxpayers would have to provide transactional data more frequently.
- Will there be a digital signature for the invoices and, if so, what is the format?
An electronic signature is mandatory for invoices issued to public administrations (B2G transactions). For B2B transactions, it is not mandatory. To facilitate the monitoring process, a QR code must be added to B2B e-invoices.
- When will e-invoicing become mandatory in Spain?
The mandate will start in July 2024 for large taxpayers with a turnover above €8 million. The implementation of e-invoices will become mandatory for all other taxpayers in 2026. Electronic invoices will also include a QR code, which will make them easy for authorities to track.
These are the expected timelines for taxpayers to start issuing e-invoices:
- Taxpayers with an annual turnover of over EUR 8 million: From July 2024 after approval by the parliament and publication on the BOE (State Official Bulletin);
- All other taxpayers: Two years after approval by the parliament and publication on the BOE, implementation will continue to 2026.
- What type of taxpayers are affected?
All Spanish VAT-paying businesses and individuals are covered by the new regulation when it comes to sending and receiving electronic invoices. For large taxpayers with an annual turnover of more than €8 million, the process will become mandatory in July 2024. The use of e-invoices will continue until 2026.
- Will there be an archiving period for the invoices?
Yes, e-invoices should be archived for a period of six years.
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