Spain’s General Directorate of Taxes (GDT) issued a binding ruling on 27 December 2024, which clarifies the application of the “Verifactu Regulation” to businesses that issue a limited number of invoices per month and where the invoices are prepared using a spreadsheet before being sent to customers.
Verifactu is an invoicing system that that requires taxpayers to use certified billing software to ensure the integrity, conservation, accessibility, legibility, traceability and unalterability of invoicing records to prevent tax fraud. Verifactu—the public tool created for this purpose—enables the submission of billing records to Spain’s tax authorities at the time they are issued (for prior coverage, see the article in the January 2025 issue of Indirect Tax News).
The Verifactu Regulation provides that taxpayers using billing software may choose between the following options:
This interpretation has significant practical implications for small businesses and professionals who have traditionally relied on spreadsheets for their invoicing needs. Given the ambiguity surrounding whether such tools constitute billing software, taxpayers should carefully evaluate their invoicing methods to determine whether they are in compliance with the new requirements. The ruling also suggests that the determining factor is not the complexity or sophistication of the tool used but rather its function in the invoicing process. If a spreadsheet or word processor is employed systematically to generate invoices, store invoicing data and manage billing records, it may fall within the scope of the Verifactu Regulation.
From a compliance perspective, businesses and professionals using spreadsheets, word processors, etc. should assess whether their invoicing practices meet the technical and functional requirements established by the regulation, including the capacity to generate a secure and unalterable record of invoices, ensuring traceability and integrity of the data.
The GDT interpretation in the ruling reinforces the importance of adapting to the new invoicing framework to avoid potential noncompliance risks. As the Verifactu Regulation continues to be implemented, further clarifications from the tax authorities may help refine the boundaries of its application and the technological solutions deemed acceptable for invoicing purposes.
Alvaro Gomez-Elvira
Ignacio Porras
BDO in Spain
Verifactu is an invoicing system that that requires taxpayers to use certified billing software to ensure the integrity, conservation, accessibility, legibility, traceability and unalterability of invoicing records to prevent tax fraud. Verifactu—the public tool created for this purpose—enables the submission of billing records to Spain’s tax authorities at the time they are issued (for prior coverage, see the article in the January 2025 issue of Indirect Tax News).
The Verifactu Regulation provides that taxpayers using billing software may choose between the following options:
- Use a billing system that allows invoices to be verified and complies with the requirements set forth in Law 58/2003 of 17 December 2003, and the regulation which guarantees the integrity, preservation, accessibility, readability, traceability, and immutability of billing records, without interpolations, omissions, or alterations that are not duly recorded in the systems; or
- A software application that may be developed by the tax administration for this purpose.
This interpretation has significant practical implications for small businesses and professionals who have traditionally relied on spreadsheets for their invoicing needs. Given the ambiguity surrounding whether such tools constitute billing software, taxpayers should carefully evaluate their invoicing methods to determine whether they are in compliance with the new requirements. The ruling also suggests that the determining factor is not the complexity or sophistication of the tool used but rather its function in the invoicing process. If a spreadsheet or word processor is employed systematically to generate invoices, store invoicing data and manage billing records, it may fall within the scope of the Verifactu Regulation.
BDO Insight
From a compliance perspective, businesses and professionals using spreadsheets, word processors, etc. should assess whether their invoicing practices meet the technical and functional requirements established by the regulation, including the capacity to generate a secure and unalterable record of invoices, ensuring traceability and integrity of the data.The GDT interpretation in the ruling reinforces the importance of adapting to the new invoicing framework to avoid potential noncompliance risks. As the Verifactu Regulation continues to be implemented, further clarifications from the tax authorities may help refine the boundaries of its application and the technological solutions deemed acceptable for invoicing purposes.
Alvaro Gomez-Elvira
Ignacio Porras
BDO in Spain