Spanish Tax Agency Updates VAT and VERI*FACTU Guidance: Third-Party Invoicing and Marketplace Models

The Spanish Tax Agency (AEAT) has updated several entries in its INFORMA database relating to VAT and the VERI*FACTU framework, incorporating criteria that largely reflect the latest binding rulings issued by the Directorate General for Taxes (DGT).

The updates cover a wide range of practical issues affecting day-to-day business operations. These include the potential classification of certain weighing devices used by businesses issuing receipts as invoicing software systems, the treatment of debit notes supporting disbursements, the place of supply rules applicable to services connected with film productions and events, the recharge of port charges, and the VAT treatment of management fees associated with ticket sales.

Among the various updates, one of the most significant developments concerns third-party invoicing arrangements in digital and marketplace environments, following the position recently confirmed by the DGT in binding ruling V0650-26.

Binding ruling V0650-26: what the DGT says about marketplaces and VERI*FACTU

In that ruling, the DGT examines a third-party invoicing structure operating through a marketplace and clarifies an issue of particular relevance for businesses that rely on digital platforms or outsourced invoicing processes. Specifically, the DGT concludes that where a valid self-billing or third-party invoicing agreement already exists in accordance with Article 5 of the Spanish Invoicing Regulations, there is no requirement to execute an additional agreement solely for the purpose of delegating compliance with the operational obligations arising under the Regulation on Invoicing Software Systems (RRSIF).

This interpretation provides greater legal certainty for businesses whose invoicing processes involve third parties, removing the need for additional contractual arrangements to comply with the new digital invoicing obligations.

The ruling also addresses the possible exclusion of certain transactions where invoices are materially issued by a third party operating under the Immediate Supply of Information (SII) regime, an area that had generated uncertainty since the introduction of the new regulatory framework.

Impact on internal invoicing processes

Beyond the specific technical issues analysed, these updates highlight the growing importance of reviewing how invoicing processes operate in practice. The interaction between invoicing software, digital platforms, external service providers and tax reporting obligations requires businesses to assess not only their contractual arrangements but also the actual functioning of their invoicing models.

As Spain continues to move towards the implementation of VERI*FACTU and broader digital tax control mechanisms, these criteria provide valuable guidance for assessing the readiness of existing invoicing procedures and identifying potential areas of risk.