Tomás Varela has three tourist apartments in the old town of Cádiz. Until now he has handed them over clean, with sheets and towels, and cleaned them again when each guest leaves. His week-long guests ask him for a change of towels halfway through their stay, and he is thinking of offering a "premium" package: cleaning every three days, fresh bed linen and a breakfast basket. He takes in about 60,000 € a year, plus VAT if any were due, and wants to know whether that package changes his taxes.
The short answer is that it can change them, and not because of the name of the package but because of what is provided during the stay.
What the law says, word for word
Article 20.One.23.º of the VAT Law exempts the letting of buildings used exclusively as homes, together with their furniture. But letter e´) excludes from the exemption lettings of furnished apartments or homes "where the lessor undertakes to provide any of the complementary services typical of the hotel industry, such as restaurant, cleaning, laundry or other similar services".
Read on its own, the sentence seems to say that any cleaning breaks the exemption. In practice it does not. The Dirección General de Tributos, the Ministry of Finance directorate that issues binding tax rulings, has repeatedly held that cleaning the property when the guest arrives and leaves, and supplying clean linen at the start, are part of making the home ready for use. What counts as a hotel service is what is provided to the guest while they are staying: periodic cleaning, changing linen during the stay, reception, catering.
Tomás's package, service by service
| Service | When | Usual reading |
|---|---|---|
| Cleaning after the guest leaves | Between stays | Preparing the property |
| Clean sheets and towels on arrival | Start | Handover ready for use |
| Cleaning fee charged separately on the platform | Between stays | Part of the accommodation price |
| Repairing a fault during the stay | During | Maintenance, not a service to the guest |
| Change of towels mid-week | During | Laundry: hotel service |
| Cleaning every three days | During | Periodic cleaning: hotel service |
| Daily breakfast basket | During | Catering: hotel service |
| Staffed reception with opening hours | During | Clear sign of a hospitality business |
| Handing over keys and a phone number for problems | Arrival | Not equivalent to a reception |
The analysis looks at the whole, but the law speaks of "any" of the services. One that is genuinely provided during the stay is enough to put the exemption at risk. Today Tomás is in the first four rows. The premium package takes him into the next three.
What happens if he crosses the line
If the letting is no longer exempt, it becomes a hospitality service. Article 91.One.2.2.º of the same law taxes it at the reduced rate of 10 %. With Tomás's figures, and assuming he cannot raise his prices:
- What he collects each year now has VAT inside it: 60,000 / 1.10 = 54,545.45 € of taxable base.
- Output VAT charged: 5,454.55 €.
- In return, he can deduct the input VAT on his costs. If his cleaning company invoices him 9,000 € plus 1,890 € of VAT, and utilities come to 3,000 € plus 630 €, he recovers 2,520 €.
- VAT payable for the year: 5,454.55 − 2,520 = 2,934.55 €.
In other words, the premium package would cost him about 2,900 € in net VAT if he keeps his rates. He would have to charge it to guests or give it up. There are also new formal obligations: registering in the tax census with Modelo 036, filing Modelo 303 every quarter, where applicable the annual summary Modelo 390, and an invoice for each guest, as explained in do I have to invoice every guest?.
There is an advantage when costs bearing VAT are large. Someone who buys and furnishes with a lot of input VAT may prefer to be taxed, although that has to be worked out with real figures and not with hunches.
Services contracted by someone else
Outsourcing changes nothing if the service is included in what you sell. If Tomás hires a company that cleans mid-stay and the guest receives it as part of the booking, the obligation towards the guest is Tomás's. It is different if the guest arranges the cleaning on their own with a third party, pays that third party and Tomás is not involved: in that case the service is not part of the letting.
The line is fine and it pays to be able to prove it: a listing in which the service does not appear, the guest's contract with the company, payment collected directly by that company. A mere "I'll give you my cleaner's number" with the money going through Tomás will not hold up.
If the platform listing says "daily cleaning included" or "breakfast", that is what the tax authorities will read first, even if in practice it is not provided. Review the wording of your listings before your invoices.
If it changes mid-year
Tomás decides to launch the package on 1 March. From that date, stays with hotel services carry VAT and the earlier ones are exempt. He has to notify registration on Modelo 036 with the real date, invoice with VAT from that day and keep the bookings of each period separate in his accounts. Bookings paid before March for later stays need particular care, because payment in advance can bring forward the point at which VAT becomes chargeable.
The furniture and appliances he bought when everything was exempt have their own treatment. Article 107 of the VAT Law provides for adjusting the deductions on capital goods during the four years following their purchase, and nine in the case of buildings, when the percentage of transactions that give a right to deduct changes. In some cases this allows part of the VAT that could not be deducted at the time to be recovered. Not every item counts: article 108 excludes, among others, those of low value.
The reverse path exists. Someone who deducts VAT because they provide hotel services and later drops them may have to pay back part of what was deducted on capital goods. Before changing model in either direction, work out that adjustment.
And the 10 % VAT that was announced
The decree-law published in the BOE on 30 September 2026 would have put stays of up to 30 nights at 10 % VAT with or without hotel services, but Congress voted it down on 2 October 2026. So this distinction keeps all its weight for VAT, as well as for income tax, where hotel services turn the letting into a business. The start date of that VAT is uncertain, with July 2028 as the outer limit under Directive (EU) 2025/516. The guide to the 10 % VAT and the VAT calculator for holiday lets show what it would do to your numbers.
What it decides and what it does not
Providing hotel services changes VAT. It does not by itself decide whether there is an economic activity for IRPF (Spanish personal income tax) purposes, or whether you have to register with Social Security: those are different questions with different criteria, analysed in do I have to register as self-employed?. Nor does the regional licence decide VAT: two homes with the same registration can be taxed differently depending on what they offer.
If you would like us to review your listings, cleaning contracts and prices before you launch a new service, you can send them with the holiday let form. We will warn you of the risks of each option; the final classification is for the tax authorities and, where appropriate, the courts.
The page on VAT and tourist homes summarises the other obligations in this line of business, and the guide on hotel services and VAT goes through the borderline cases in more detail.