During a meeting of the Council of Ministers on November 30, 2021, a proposal for a law was approved, which would introduce e-invoices in B2B transactions over two phases. Parliament and Senate must pass the proposal before it can become law according to Spanish legislative procedure.

  • phase 1 Within 1 year of the law being approved by parliament, applies to large companies that issue invoices with total amounts exceeding EUR 8 million (i.e., annual turnover for invoices issued);
  • Phase 2 within 3 years of parliamentary approval for all other companies.

In the proposal, businesses would be required to exchange e-invoices and store e-invoices for four years. A "National Debt Observatory" will also be created by the Spanish government, which will monitor and analyze payment transactions.

A program called Digital Toolkit has also been launched by the Spanish government to help businesses adopt the necessary technologies to implement an e-invoicing system.

Starting January 1, 2024the province of Biscay requires taxpayers to electronically declare Economic Operations Record Books (LROE).

The LROE must be filed through the new TicketBAI system by the 25th day of each trimester before VAT payments can be settled. LROEs must be filed monthly by large companies and selected taxpayers.

The provincial council of Biscay initially planned to implement the 'BATUZ Strategy' effective January 1, 2022, which consisted of the following:

  • Implementation of “TicketBai” e-invoicing system;
  • Book registry (LROE) for individuals and legal entities correspondingly; and
  • Prefilled templates of VAT and Income tax returns.

Recently, the Biscayan government delayed the mandatory implementation to January 1, 2024.

Tax service providers (i.e., those who provide tax services to other taxpayers) who operate as collaborator entities of the Biscay tax administration will be required to use TicketBai starting April 1, 2022, and July 1, 2022, respectively. In the upcoming months of 2022 and 2023, this obligation to comply with TicketBai will be gradually extended to other taxpayers. The system is already available in Álavafor those taxpayers who voluntarily opted for it and will be in Guipuzcoaas of July 1, 2022.

On February 21, 2022, Spain published a Draft Royal Decree approving the Regulation governing the requirements for electronic or computer software and systems that support the invoicing processes of traders and professionals, and the standardization of invoicing record formats. This Draft Regulation would implement the obligation on all traders, effective January 1, 2024, to have electronic invoicing systems in place and to submit their records on a continuous (albeit, for the time being, voluntary) basis to the State Tax Agency.

In addition, both the producers and traders of computer systems should comply with the new invoicing software obligation as of the day following the date on which this future Draft Regulation is published in the Official State Gazette.

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