- 16-minute read
VAT accrual in Spain: when to
declare your sales and when to issue the invoice
- Oct 19, 2026
You finish a one-off service on 29 September, issue the invoice on 6 October and get paid in November. Which quarter does that VAT belong to? If the transaction falls under the general VAT regime and you file quarterly returns, the tax belongs to the third quarter. In other words, an October invoice can belong to the previous quarter.
The explanation lies in accrual: under Article 75 of the Spanish VAT Act (Law 37/1992), the tax accrues when the service is rendered, not when it is invoiced or paid. The example assumes there are no advance payments and no special rule applies, and it will serve as a thread throughout this article to see when the tax arises for each type of transaction, how long you have to invoice and how to correct an allocation error.
01. What accrual is and why it matters
Accrual determines when the tax liability for a transaction arises. It should not be confused with the moment you file the return or pay the resulting amount.
Under the general regime, the VAT accrued is included in the return for the corresponding period, together with any applicable deductions. So declaring a sale does not necessarily mean paying its full VAT: the result also depends on the deductible input VAT and the other components of the return.
02. When VAT accrues by type of transaction
Supplies of goods
As a general rule, Article 75.One.1 of the VAT Act places accrual at the moment the goods are placed at the buyer’s disposal. If you deliver goods on 30 June, deferring payment does not by itself move the accrual to another period. It is advisable to keep documents that prove when the delivery took place.
Supplies of services
Under Article 75.One.2, services accrue when they are rendered, performed or carried out. For a one-off service, its physical completion usually determines that moment, even if the invoice is issued later.
However, there are specific rules for, among others, certain construction works and certain continuous services subject to the reverse charge. The completion rule should therefore not be applied automatically to every long-term contract.
Leases and other continuous transactions
For leases, utility supplies and other continuous (successive) transactions, Article 75.One.7 links accrual to the moment each part of the price becomes payable. What matters is the agreed due date, not actual payment.
If no price has been agreed, the due date has not been set or the payment interval exceeds one calendar year, accrual takes place on 31 December for the proportional part corresponding to the elapsed period. Intra-Community transactions may follow different rules.
Advance payments
Article 75.Two provides that advance payments accrue the tax when received, for the amounts actually collected. Thus, an amount received in March on account of a service to be performed in May may generate VAT in the first quarter. This rule does not apply to advance payments for intra-Community supplies of goods covered by Article 25 of the same Act.
The table summarises the general rules:
| Type of transaction | General accrual rule | Provision (VAT Act) |
|---|---|---|
Supply of goods |
When the goods are placed at the buyer’s disposal |
Art. 75.One.1 |
Supply of services |
When the service is rendered, performed or carried out |
Art. 75.One.2 |
Leases, utility supplies and other continuous transactions |
When each part of the price becomes payable |
Art. 75.One.7 |
Advance payments |
On receipt, for the amounts actually received |
Art. 75.Two |
03. Which return each transaction goes in
Under the general regime, identifying the accrual date allows you to allocate the VAT to the corresponding return period. In the opening example, the service completed on 29 September is included in the third-quarter return, even though the invoice is issued on 6 October. If you file monthly, it belongs to the September period.
Put simply: delaying the invoice does not let you choose a later return period.
04. What this means for the invoice issue date
How long you have to issue the invoice
Article 11 of the Invoicing Regulation, approved by Royal Decree 1619/2012, sets the general rule that the invoice must be issued when the transaction takes place. Where the customer is a business or professional acting as such, it must be issued before the 16th of the month following the month of accrual.
This invoicing window does not shift the period in which the VAT is declared. There are also specific rules for intra-Community transactions, summary invoices and transactions under the cash accounting scheme.
Issue date and transaction date
Article 6 of the Invoicing Regulation requires the invoice to show the issue date and, where different, the date on which the transaction took place or the advance payment was received. In the example, the invoice issued on 6 October must state that the service was performed on 29 September.
Leaving out this information does not legally turn the transaction into an October transaction or change its accrual. However, it can make the transaction harder to identify correctly and requires the invoice to be corrected.
Summary invoices
Article 13 of the Invoicing Regulation allows several transactions carried out for the same customer within the same calendar month to be grouped into a single invoice. As a general rule, it must be issued no later than the last day of that month; if the customer is a business or professional acting as such, it may be issued before the 16th of the following month. Grouping transactions in one document does not alter the accrual rules applicable to each of them.
05. When the customer can deduct the VAT
It is worth distinguishing between when the right to deduct arises and when it is exercised. Under Article 97 of the VAT Act, the invoice or supporting document is an essential requirement, and Article 99 governs the timing of the deduction.
It should not be claimed, however, that receiving an invoice in October always means deducting it from the fourth quarter onwards. Where the substantive requirements are met and the invoice is received before the return for the accrual period is filed, deduction in that same period may be admissible. The specific circumstances and any applicable special rules must be checked.
06. How to correct a transaction declared in the wrong period
Declaring VAT in a period later than the correct one may require the affected returns to be regularised. For monthly periods from September 2024 and quarterly periods from the third quarter of 2024, the general rule is to file a corrective self-assessment , under Article 74 bis of the VAT Regulation.
It is therefore no longer correct to treat the supplementary return as the general solution for current errors in Form 303. Late correction may carry the surcharges and late-payment interest applicable in each case.
07. What changes under the cash accounting scheme
The special cash accounting scheme is optional and subject to requirements. Article 163 decies of the VAT Act provides, among them, that the business’s turnover in the previous year must not exceed two million euros.
Under Article 163 terdecies, the tax accrues upon full or partial payment or, if payment is not received, on 31 December of the year following the transaction. The scheme also defers the right to deduct of the business applying it until it pays its suppliers, subject to the same time limit, and it affects the deduction available to its customers for the transactions covered.
The cash accounting scheme does not let you wait for payment to invoice.
Article 11.3 of the Invoicing Regulation maintains the obligation to issue the invoice when the transaction takes place or, where the customer is a business or professional acting as such, before the 16th of the month following the transaction. The invoice must include the wording “régimen especial del criterio de caja”. Deferring accrual is therefore not the same as deferring the invoicing of the transaction indefinitely.
08. How to recover the VAT on an unpaid invoice
Article 80.Four of the VAT Act allows the taxable amount to be reduced for bad debts if its conditions are met. As a general rule, one year must pass without payment; if the creditor’s turnover in the previous year did not exceed €6,010,121.04, it may choose six months or one year.
The debt may be claimed through the courts, by notarial demand or by any other means that provides reliable proof of the claim. The adjustment must be made within six months following the applicable period, with specific rules for deferred-payment transactions and other special cases.
Recovery requires meeting the formalities
An unpaid invoice is not enough. Article 24 of the VAT Regulation requires, among other things, issuing and sending a corrective invoice and notifying the Spanish Tax Agency (AEAT) electronically of the adjustment within one month of its issue. The exclusions and limitations in Article 80 of the VAT Act must also be checked, particularly where there are guarantees, related parties or insolvency proceedings.
09. Invoicing systems and traceability
The requirements for computerised invoicing systems strengthen the integrity and traceability of records. They should not be confused with an obligation to use the VERI*FACTU mode: automatically sending every record to the AEAT is one way of operating the system.
In any case, recording the issue of an invoice does not replace determining the accrual date, nor does it remove the need to show the transaction date correctly.
10. Conclusion
The key is to separate three moments: when the transaction takes place, when the invoice is issued and when payment is received. Under the general regime, accrual determines the return period; the invoicing rules establish when and how to document the transaction; and later payment does not in itself change that accrual.
Reviewing, at the close of each period, completed transactions not yet invoiced, advance payments received and the dates shown on invoices helps prevent allocation errors. Special schemes and transactions with specific rules always require a dedicated review.
