Spain: Draft e-invoicing regulations published

Taxpayers have until 10 July 2023 to submit observations.

Taxpayers have until 10 July 2023 to submit observations.

The Ministry of Finance on 15 June 2023 published for consultation draft electronic invoicing (e-invoicing) regulations. Taxpayers have until 10 July 2023 to submit observations.

According to Law 18/2022, which was adopted last year, taxpayers with an annual income of €8 million must implement the e-Invoicing system within one year of the enactment of the regulations. For all other taxpayers and professionals, the implementation will take effect within 24 months. Once the regulation is approved, e-invoice recipients will be required to respond to the issuer about the acceptance, rejection, cession, and complete or partial payment of the invoice received. However, the draft regulation states that taxpayers with an annual gross income of €6,010,121.04 must comply with this response requirement within 36 months of the publication of the regulation, while those with an annual income below this threshold will be required to comply with this requirement within 48 months. According to the draft regulation, taxpayers would be able to comply voluntarily with the e-invoicing mandate before the effective date applicable to them.

Among other things, the draft regulations provide details on what constitutes an e-invoice between VAT-registered businesses. The draft regulations further mandate taxpayers to use private e-invoicing platforms or a public e-invoicing solution that the tax authorities will need to set up for those that cannot use a private platform. In this respect, the draft regulations also outline the requirements for operating as an e-invoice exchange platform.


For more information, contact a KPMG tax professional:

Kathya Capote Peimbert |

Ramon Frias | 


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