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Spanish FAQ on real-time reporting published

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Spanish FAQ on real-time reporting published

Following our announcement last month of the real-time VAT reporting obligation in Spain, the Spanish authorities clarified a number of open questions related to these changes. This new information is included in a 34 page Frequently Asked Questions document issued by the Spanish tax authorities.

Here is a summary of the additional information published by the Spanish tax authorities (we selected those questions more relevant for foreign businesses):

  • Non-established companies are also required to submit VAT reports in real time.
  • Companies currently registered in the monthly refund scheme (REDEME) willing to opt-out of the system in order to avoid the new obligation will benefit from an administrative tolerance allowing de-registrations from between 1 and 30 of June 2017. Otherwise, they will need to wait until November 2017.
  • Taxpayers will be able to check in the authorities´ online system all reported ledgers as well as all reconciled ledgers by the authorities. This means that the Spanish tax authorities will provide their reconciliation between the amount received from the taxpayer and the amounts reported by its suppliers and customers. 
  • Those affected by the new obligation will not need to submit the 2017 Annual VAT return (modelo 390) and 2017 Annual Sales and Purchase Listings (modelo 347).
  • Identifying invoices cancelled by credit notes will be optional. However, where a credit note is reported, there will be a separate code for the reason of correction.
  • Where the client or supplier do not have a Spanish VAT number, there will be an additional section to report foreign numbers.
  • Only Euro amounts can be reported.

The complete document of Questions and answers on real-time electronic ledgers is available in the website of the Spanish tax authorities.


  • By Marosa EU VAT
  • Published 29/01/2017 21:30