10 % VAT on holiday lets: start date uncertain · outer limit July 2028. On 2 October 2026 Congress voted down Royal Decree-law 26/2026, which had set 1 December 2026, so that date no longer stands. The outer limit comes from Directive (EU) 2025/516: July 2028. We have it ready for whenever it comes in. Meanwhile we keep handling what is already compulsory today: Form 303 for the reverse-charge VAT on Airbnb and Booking fees, the EU VAT number (ROI) and Form 349.
Who this is for
This guide is for an owner who charges VAT on a holiday let. Today that means an owner who provides hotel-type services; once the 10 % VAT on lets of up to 30 nights comes in, it will mean almost every owner letting for short stays. Its start date is uncertain since Congress voted the decree-law down on 2 October 2026, with July 2028 as the outer limit. An exempt rent never appears on form 303 — but the platform commission does, which is covered further down. The background is in the 10 % VAT on holiday lets.
Whether you are in scope today is decided by article 20.Uno.23 of Act 37/1992 and its carve-out for hotel-type services, set out in hotel-type services and VAT. Read that first if you are not certain which side of the line you sit on. Being wrong about that is far more expensive than filling in a box incorrectly.
How the return is organised
Form 303 always has the same three parts, whatever the numbering of the boxes that year:
- Output VAT — what you charged your guests. It goes in by rate: one line for 10 %, another for 21 %, each with its own taxable base and its own tax. Accommodation with hotel-type services is taxed at 10 %, and so will short stays without them once the new rule arrives; anything you charge on separately may sit at a different rate.
- Input VAT — the VAT on your costs. Current expenditure is kept apart from capital goods, because capital goods carry their own multi-year adjustment rules.
- The result — output less input. Negative results are carried forward against the following quarters, or claimed as a refund in the final quarter of the year.
The Spanish tax office renumbers the form from time to time. What matters is not memorising a box but knowing which concept belongs in which block. We check the numbering against the official form for the year in question before every filing, and you should distrust any guide that leads with box numbers and no date.
Input VAT: where almost everybody goes wrong
Not all the VAT on your invoices is recoverable in full. Three conditions have to hold at once: a complete invoice in your name and with your NIF, a cost genuinely connected to the activity, and — above all — proportion.
If the property was let 120 nights out of 365, you cannot recover the whole year's VAT on electricity. For the rest of the time the property was at your own disposal, and VAT follows the same logic as income tax here. That split by days is the first thing a review looks at, and the reason we keep a booking register with dates rather than a monthly total. The mechanics are in nights let and apportioning costs.
A quarter with numbers
| Item | Net | VAT | Business use | Recoverable |
|---|---|---|---|---|
| Electricity for the quarter | 180.00 € | 37.80 € | 33 % | 12.47 € |
| Cleaning between guests | 420.00 € | 88.20 € | 100 % | 88.20 € |
| Platform commission | 560.00 € | 117.60 € | 100 % | 117.60 € |
| A new sofa | 900.00 € | 189.00 € | 100 % | 189.00 € |
Cleaning between guests goes in at 100 % because it only happens because of the letting. Electricity does not: it is consumed while the flat stands empty and while you are in it. The sofa is recoverable in full in the quarter of purchase, but it is a capital good, so if the use of the property changes substantially within the adjustment period, part of that recovery can be clawed back.
The platform commission
Airbnb Ireland and Booking.com B.V. are established in other EU member states. When they deduct commission they are supplying you an intermediation service, and under the reverse charge the recipient accounts for the VAT. That means you declare Spanish VAT on the commission, on form 303, and report the transaction on form 349.
This applies even while holiday lets are exempt, because the exemption attaches to the letting, not to your status as a business, and an exempt owner cannot deduct the VAT they charge themselves. Once short stays carry 10 %, that VAT will be deductible and the whole thing will wash through on the same return — but the ROI registration and form 349 are required either way. The full mechanics are in form 349 and platform commission.
Partial deduction, if you also have exempt lets
An owner with one flat on short stays and another on a long residential tenancy has taxable activity and exempt activity at the same time. That triggers the partial-deduction rule: input VAT on costs common to both is recoverable only in the proportion that transactions carrying a right to deduct bear to the total. Costs attributable wholly to one side go wholly to that side. In practice it means running two sets of books in parallel, and it is the part of any VAT change that adds the most work to bookkeeping that used to be simple.
Filing dates and the annual summary
Form 303 is filed in the first twenty days of April, July and October, and the fourth quarter to 30 January. If you pay by direct debit the window closes a few days earlier, which is a detail worth building your internal calendar around rather than discovering in January.
The annual summary, form 390, goes in each January and has to reconcile to the sum of the four quarters. If letting urban property is your only activity you are in principle exempt from it and give the year's totals in the fourth-quarter 303 instead. When it does not reconcile, it is usually because a quarter was filed with a figure that later changed. That is worth fixing yourself, because a mismatch between the summary and the quarters is one of the easiest discrepancies for a computer to spot.
If the obligation is on your census record and a quarter has no transactions, you file a nil return. Not filing when you are required to is an infringement in its own right, even where the result is zero. If the activity has genuinely ended, the obligation has to be removed from the census on form 036 — it does not lapse on its own.
Fixing a quarter you have already filed
If you underpaid, the route is a supplementary return for that quarter, which carries the late-filing surcharge: 1 % plus a further 1 % for each complete month of delay, rising to 15 % plus interest after twelve months. If you overpaid, the route is a request to rectify the return and recover the overpayment, open for four years. The direction of the error decides the procedure, and in both cases moving first matters: once a formal request arrives from the tax office, a surcharge turns into a penalty.
Questions we get asked about your holiday let
What if a quarter has no income at all?
You file it at nil. The obligation is on the census, not on whether anything happened.
Can I recover the VAT on furniture?
Yes, if the property is used in a taxable activity that is not exempt, and in the corresponding proportion, like any other cost. Furniture is a capital good, so keep the invoice and the date.
My return is in refund. When do I see the money?
The refund is claimed in the fourth-quarter return. The tax office then has six months to pay it, and in practice a first-time refund claim is often the trigger for a request for documentation.
I am a self-employed professional as well. Is it the same return?
It is the same form, but the profile is different enough that we cover it separately in form 303 for the self-employed.