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Spanish mandatory B2B e-invoices January 2024 update

Spain to add live B2B e-invoices to existing SII real-time reporting; rollout between 2024 and 2026; legal obligation on ERP and billing system vendors to offer compliant systems

Spain’s lower House of Parliament, the Congress of Spain, has ratified a  technical specification Bill launching mandatory B2B e-invoices, with government pre-clearance with AEAT, the state tax agency. It has now been Gazetted today, 29 September. The government now has six months to issue technical specifications and regulations.

This would only apply to resident Spanish businesses with a fixed establishment from 24 January 2024. B2G e-invoicing is already mandated in Spain where invoices to public bodies are above €5,000.

An invoice QR code requirement has been added. The obligation will start first for large taxpayers from 24 January 2024..  All other businesses would be mandated early 2026.

EU VAT in the Digital Age reforms include a channel for harmonised Digital Reporting Requirements (DRR) and  Continuous Transaction Controls (CTC) by EU states. This grew from the 2020 EU Tax Action Plan  proposals for a fairer and more efficient EU tax regime.

Spain’s SII live invoice reporting regime was introduced in July 2017. This new e-invoicing regime may not replace SII since it is not part of the VAT or invoicing laws. Instead, it is being introduced to existing 2007 legislation around “promotion of the society of digital information).

2024-26 two-phase roll out of B2B e-invoices

The rollout will likely be as follows:

  • 2024  large tax payers (turnover above €8 million); and
  • 2026  all other taxpayers.

It is likely that any possible government mandated plan would be based on the pre-clearance model, and be supported by the Digital Toolkit for small businesses. A public consultation is now being launched.

Spain has already indicated that it will require QR Codes included to help digitally track invoices. The Royal Decree plans a legal requirement for software developers and retailers to ensure their accounting and similar systems are able to comply with the new e-invoicing requirements and are able to transmit prescribed data to the tax authorities.

E-invoicing to fight VAT Gap

The proposal to extend mandatory e-invoices to all businesses and non-incorporated businesses for business-to-business transactions aims to improve the efficiency of business operations but also to help fight VAT fraud. The European Commission’s VAT Gap estimates that Spain lost €6.8 billion in expected Value Added Tax revenues.

Italy’s SdI e-invoice regime has shown remarkable success in closing its VAT Gap by almost 10% in just one year. France and Poland are to follow with 2023 being a big year for European e-invoice initiatives. The EU e-invoice consultation is well underway.

VAT Calc’s in real-time global Calculator and Auditor  services produce instant and accurate tax calculations into your e-invoice, ERP, billing or e-commerce systems.

Europe e-invoicing and live reporting

Country Date Comments (click for details)
EU e-invoice proposals 2028 Digital reporting and e-invoicing harmonisation
Albania Jan 2021 Authorised e-invoice software and pre-clearance
Belgium 2024-25 Phased introduction of B2B e-invoices
Bulgaria 2023 Public consultation on pre-clearance model e-invoice
Denmark 2024 Digital record keeping obligations
Finland Apr 2020 Customer option to require B2B e-invoices
France Jul 2024 E-invoicing and e-reporting for B2B and B2C
Germany 2024 (?) New government e-invoice 'as soon as possible' to fight fraud
Greece Oct 2021 myData summary invoice and ledger reporting
Hungary Jul 2018 RTIR live invoice reporting. No govt pre-clearance required
Italy Jan 2019 Pre-clearance SdI e-invoicing
Ireland TBC Public consultation underway
Latvia Jan 2025 B2B e-invoices based on PEPPOL
Lithuania ? E-invoicing platform being scoped
Poland Jul 2024 B2B mandated e-invoicing
Portugal Jan 2024 Certified invoicing software for non-residents
Jan 2024 ATCUD digital invoice signature for non-residents
Romania Jul 2022 RO e-invoicing implementation
Russia TBC Extension of Traceability Model to B2B on hold
Serbia Jan 2023 B2B e-invoicing
Slovakia 2024 B2B and B2C e-invoice rollout
Slovenia 2023 ? e-SLOG B2B proposal stalled
Spain 1 Jul 2017 SII live invoice and book reporting
Spain 2 2024 Pre-clearance B2B e-invoices; supplement to SII
Sweden 2024? PEPPOL based mandatory e-invoicing
Turkey Jan 2014 e-invoice e-Fatura and e-Arşiv
UK Apr 2022 MTD for VAT extended to 1.1million taxpayers


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