Providing hotel-type services, or not providing them

The dividing line is not cleaning, it is when you clean

Letting residential property is exempt from VAT under article 20.Uno.23 of the Spanish VAT Act. That same article opens an exception: there is no exemption where the landlord undertakes to provide ancillary services characteristic of the hotel industry. The entire VAT debate around holiday letting fits inside that one sentence.

And the line does not run where owners expect. Almost everyone asks the same thing: if I clean, do I have to charge VAT? The answer depends on when you clean. Cleaning the apartment between one guest and the next is preparing the property for handover, exactly as a landlord repaints before a three-year tenancy. That is not a hotel service. Cleaning the room on the Wednesday, while the guest is still staying there, is.

What counts and what does not

This is a hotel-type service	This is not
Periodic cleaning of the interior during the stay	Cleaning on arrival and on departure
Changing bed linen and towels during the stay	Providing clean linen on arrival and washing it once the guest has gone
A reception desk and continuous attention to the guest	Handing over keys, in person or through a key safe
Catering: breakfast, meals, room service	Leaving the cupboards stocked on day one
Luggage storage and laundry during the stay	Maintenance and repairs to the property
Hotel-style shared services provided continuously	Utilities, wifi and the cleaning of the building's common parts

What changes depending on which side you land

Without hotel-type services the let is exempt, whether it lasts three nights or three months. You charge no VAT, you file no periodic VAT returns for the rent and, in exchange, you recover not one euro of the VAT you pay out: not on the refurbishment, not on the furniture, not on the new appliance, not on the commission the booking platform charges you.

With hotel-type services the letting is taxable at the reduced rate applicable to hospitality services. You charge VAT to the guest, you file quarterly returns and the annual summary, and you deduct the VAT you have paid on everything genuinely used in the activity. Once the short-stay rule arrives, every stay of up to 30 nights will sit on this side too.

Which side suits you

It is worth remembering that this is not a box you tick: you fall on one side or the other according to what you genuinely undertake to provide. That said, where there is room to design the offering, the decision looks like this:

• Being taxable suits you when there is large, imminent input VAT: a full refurbishment, furnishing a newly bought flat from scratch, buying a new-build with VAT on the purchase price. The deductible VAT on a serious refurbishment can exceed several years of output VAT.
• Exemption suits you when the property is already finished, running costs are low and your guest is a private individual who deducts nothing. Charging VAT raises your final price against the flat next door, and the filing obligations do not pay for themselves.
• Forcing the classification does not suit anyone. Inventing a reception desk in order to recover the VAT on a refurbishment is the kind of structure that collapses at the first enquiry, because a service that is not really provided leaves no trace anywhere: not in the costs, not in the rotas, not in the reviews.

The 21 % that was talked about, and the 10 % that was voted down

For a long while the talk was of an initiative to subject holiday letting to the standard 21 % rate. What appeared in the BOE on 30 September 2026 was something else: Royal Decree-law 26/2026 kept the exception for hotel-type services and added a second one, the let to the same tenant that does not exceed 30 nights, both at the reduced rate of 10 %. It would have applied from 1 December 2026, but Congress rejected it on 2 October and it lapsed.

What that does to this comparison is leave it whole for the time being. For stays of up to 30 nights the exempt column is still there, and the choice described above is a live one whatever the length of the let. The second exception is expected back, because Directive (EU) 2025/516 treats short lets like hotel accommodation with July 2028 as the outer limit, and from then the choice will narrow to lets of more than 30 nights. Structures meant to last years are worth rereading against that horizon rather than against a newspaper headline, and the detail is in the 10 % VAT on holiday lets.

A note for owners who live abroad

Being non-resident changes nothing in this analysis: VAT follows where the property is, not where the owner is. What it does change is everything alongside it — the rate applied to your rental profit, whether costs are deductible at all, and the imputed income for the days nobody is in the flat. Those sit on a different page: letting it or leaving it empty.

The in-between case: providing hotel-type services, or not providing them

The owner who never meets the guest. It is extremely common among people who live abroad, and the table does not cover it, because there are two overlapping grants of use and each one has its own answer. The owner does not let to the traveller: he hands the property to a management or operating company which markets it on its own account and settles a sum with him. That first grant is not the letting of a dwelling to meet anybody's housing need; it is the handing over of a property to an operator who will exploit it commercially, and its treatment is not resolved by asking whether anyone cleans halfway through a stay. The second grant, from the manager to the guest, is the one examined under article 20.Uno.23 of the VAT Act.

Signing one of those contracts without reading the two levels together produces incoherent results: you treat what you invoice the manager as exempt while the manager charges the traveller VAT, or the reverse. The name on the document is no help either. There are papers headed «management mandate» that share risk and price like a lease, and papers headed «lease» under which the owner still carries the cost of every empty night. What is looked at is the real allocation of risk: who sets the price, who answers to the customer, and what each party actually takes. If yours is in Spanish and you signed a translation, ask for the version that was actually executed.

There is a second in-between case: the same property sold two ways. Some bookings go out bare and others with breakfast and daily servicing, depending on the channel. Exempt and taxable transactions then sit side by side, which obliges you to separate the income and apply the pro rata rule to the input VAT you cannot attribute to one or the other. It is perfectly legitimate. It has to be run on proper records, not from memory.

What to look at before deciding on providing hotel-type services, or not providing them

The classification is not chosen in a box, but the file that supports it can be built. To be able to say which side you are on, these are the documents, and they are worth gathering before the first return rather than after the first letter:

• The listing exactly as it reads today, captured as images. It is the most accessible evidence the authorities have and the first thing they look at.
• The platform or management contract, complete and with its schedules of services, so that it is clear who is bound to do what for the guest.
• The instructions and the invoices for the cleaning, with dates and times on them. What separates cleaning at changeover from cleaning during a stay is the days on which someone enters the property, and that is proved with worksheets, not with explanations.
• The input VAT you expect over the coming years: refurbishment, furniture, professional fees, commissions. If serious building work is on the horizon, the figure changes the whole conversation.
• Your census registration and the heading you have been declaring under, which frequently does not match what is actually being done on the ground.
• The commission invoices from foreign platforms for recent years, because that is where any unreported reverse charge shows up.

And one point almost nobody has in mind: the VAT recovered on a refurbishment or a purchase is not settled in the first year. Capital goods are adjusted over several later years — property over the longest period — if their use changes. Recovering the VAT today because hotel-type services are provided today, and ceasing to provide them next year, means paying part of it back.

What we do with providing hotel-type services, or not providing them

We read what you are actually offering — the listing, the platform contract, the instructions you give the person who cleans — and set it against what you have been declaring. That tells us whether you are where you think you are. Then we look at whether staying there suits you, with the expected input VAT of the next few years on the table.

We do not promise an outcome: this area has acknowledged grey zones, and when your case falls in one we say so and explain the risk on each side. The full line is on holiday lets, and the form asks about the services one by one, which is exactly what has to be known.