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.
What is happening when Airbnb deducts its commission
Airbnb Ireland UC and Booking.com B.V. are businesses established in other member states of the European Union. When they charge you a commission they are supplying you an intermediation service. For services between businesses in different member states, the VAT is due in the country of the recipient and is accounted for by the recipient: that is the reverse charge, in article 84.Uno.2 of Act 37/1992.
Translated: on that commission, the person who has to declare Spanish VAT is you.
A let without hotel-type services is exempt, but the exemption attaches to your letting, not to your status. You are still a taxable person for VAT purposes, and the reverse charge reaches you all the same. That is why an owner who had never charged a cent of VAT could still owe a filing every quarter.
What has to be done, in order
- Register on the ROI, the Spanish register of intra-EU operators, using form 036. Doing so gives you a VAT identification number — your NIF prefixed with ES — and puts you on VIES, the European database that any business can query.
- Give that number to the platform in your account profile. From then on they stop charging you their own country's VAT, because they can see you are a business accounting for it yourself.
- File form 349, the recapitulative statement of intra-EU transactions, reporting the services you acquired. For most owners this is quarterly.
- Reflect it on form 303: the transaction is self-charged as output VAT and, depending on your regime, may or may not be deductible on the same return. For an exempt letting, which is the position of most holiday lets today, it is a genuine cost; once stays of up to 30 nights carry VAT at 10 %, it will be deductible.
How much money this is
With 20,000 € of Airbnb income and commission at 15 %, you are looking at 3,000 € of commission and 630 € of VAT to self-charge over the year. While the letting is exempt, those 630 € are cost. Royal Decree-law 26/2026 would have taxed stays of up to 30 nights at 10 % from 1 December 2026, which made the same 630 € a year recoverable, but Congress voted it down on 2 October 2026. When the measure does arrive — July 2028 is the outer limit — the reverse charge will wash through to nil. That is one of the few genuinely favourable side-effects of the 10 % VAT on holiday lets.
Which platforms, and which invoices
The rule follows the place the supplier is established, not the brand. Airbnb invoices Spanish hosts from Ireland and Booking from the Netherlands, so both fall squarely in. Other platforms vary, and some invoice through a Spanish establishment, in which case they charge you Spanish VAT directly and there is nothing to self-charge. The way to tell is the invoice itself: look at the issuing entity, its country and whether any VAT has been added. If the document says nothing about VAT and shows an EU VAT number that is not Spanish, you are in reverse-charge territory.
The same logic catches services you may not think of as platform costs: channel managers, dynamic pricing tools, a booking engine, advertising bought from a company established elsewhere in the EU. Each of them is an intra-EU acquisition of services and each belongs on form 349.
A supplier established outside the European Union — a US software company, for instance — also triggers a reverse charge on your form 303, but it does not go on form 349, which only covers intra-EU transactions. Mixing the two is a common error and it produces a statement that will never reconcile against what your suppliers report.
The other side: what the platforms report about you
Since the EU-wide reporting rules for digital platforms came in, Airbnb, Booking and the rest report to their own tax administration what each host earned, and that information is exchanged with Spain. So the income side of your file is already visible. An owner who has been receiving platform payouts for years while appearing nowhere in the intra-EU register is a straightforward mismatch to spot.
And if you have gone years without doing it
That is the ordinary case, not the exception. Voluntarily regularising the open years — the last four, broadly — carries a surcharge but no penalty. The surcharge starts at 1 % and rises by one point for each complete month, to 15 % plus interest after twelve months. If a formal request from the tax office arrives before your filing does, the surcharge is replaced by a penalty, and penalties start at 50 % of the tax not paid. The difference between the two routes is usually an order of magnitude; you can see it in euros in the surcharge calculator.
There is a second, quieter benefit to coming forward: registering on the ROI has no retroactive effect, so the sooner you are on it the sooner the platform stops charging you Irish or Dutch VAT that you would then have to chase them for.
Does registering make you more visible?
Being on the ROI when you should be is simply correct. What attracts attention is the opposite: taking money from Airbnb for years without appearing anywhere. We would rather you heard that plainly than discovered it from a letter. If you want the recurring filings handled, that is what the monthly fee covers; if you want the back years looked at first, that is a one-off piece of work we quote before starting.
Questions we get asked about your invoicing abroad
Do I file form 349 in a quarter with no commission?
If there are no intra-EU transactions in the period, the statement is not filed. It is one of the few Spanish returns with no nil version.
What about Vrbo and the smaller platforms?
It depends where they invoice from. If the invoice comes from a business established in another member state, the rule is identical.
Can I deduct the VAT I self-charge?
Only if your activity carries a right to deduct. With hotel-type services, taxed at 10 %, it does. For an exempt letting, which today includes short stays without those services, you declare it and it stays a cost; if you mix both, the deduction is apportioned.
Does this affect my income tax?
Separately, yes: the commission is a deductible cost of the letting in full, because it only exists because of the booking. See deductible costs.
What a query about this actually looks like
It rarely arrives as a demand for tax. It arrives as a letter saying that, according to information supplied by another Member State, you received intra-EU services in a given quarter, and asking you to explain why nothing was declared. The figure in the letter is the one the platform reported in its own country, and it is usually right.
Answering that well means producing the commission invoices, the VIES validation for the relevant dates, and the returns as they should have been filed. Answering it badly — or ignoring it — turns an omitted information return into a review of how you treated those commissions for VAT, which is a much larger conversation.