Álvaro Gil owns two tourist flats in Cádiz. The one on Calle de la Palma he lets as it is: he hands over the keys, leaves the flat clean and cleans it again when the guest leaves. The one in the Santa María district he offers with daily cleaning during the stay, a change of towels and breakfast in the fridge. A German guest asks him for an invoice on leaving, another guest asks for one in the name of her company in Seville, and Álvaro realises he has never issued a single one. The answer to his question is different for each flat.
First, what VAT each flat carries
Article 20.One.23 of the Spanish VAT Act exempts the letting of homes, but its letter e′) excludes from the exemption the letting of apartments or furnished homes where the landlord undertakes to provide any of the complementary services typical of the hotel industry, such as restaurant, cleaning, laundry or similar services. With that rule:
- The flat on Calle de la Palma, with no services during the stay, is in principle exempt. Cleaning between guests does not turn it into a hotel business.
- The Santa María flat, with daily cleaning and breakfast, provides hospitality services and is taxed at the 10 % rate of article 91.One.2.2.
Exactly where the line lies, and which services cross it, is explained in when cleaning and bed linen change the VAT. Here we start from that classification, because the obligation to invoice depends on it.
The exempt flat: an invoice only in certain cases
The Invoicing Regulation (Royal Decree 1619/2012) requires businesses to invoice all their transactions, including exempt ones, but its article 3.1.a) excludes from that obligation transactions exempt under article 20 of the VAT Act, except for a closed list of paragraphs in which number 23 does not appear. The exception has an exception of its own: article 2.2 requires an invoice in every case where the recipient is a business or professional acting as such, where it is a legal person or a public authority, or where the recipient requires it in order to exercise a right of a tax nature.
For the flat on Calle de la Palma that means:
| Who is staying | Obligation to invoice? | What it must include |
|---|---|---|
| Private tourist who does not ask for one | No | Keeping the booking and the payment is enough |
| Private individual who asks for one without a tax right behind it | No, although one may be issued | If issued, with the exemption statement |
| Company booking for an employee | Yes | Full invoice, with the exemption statement |
| Association or foundation | Yes, as a legal person | Full invoice, with the exemption statement |
When it is issued, the invoice carries no VAT amount. Article 6.1.j) of the regulation requires a statement that the transaction is exempt, citing the provision of the law or of the directive, or with an equivalent indication. Writing "VAT 0 %" is not the same thing and may confuse whoever receives it.
The flat with services: an invoice every time
For Santa María there is no exception: each stay is a supply that is taxable and not exempt, and it has to be documented. The question is with which kind of invoice. Article 4.1 allows a simplified invoice when the amount does not exceed 400 €, VAT included. Article 4.2 raises the limit to 3,000 € for certain activities, among them hospitality and catering services of "restaurants, bars, cafés" and similar establishments. Whether a serviced flat fits into that list is a matter of interpretation, and the prudent reference, until the criterion has been confirmed for the specific case, is 400 €.
Two of Álvaro's stays in Santa María, with prices including VAT:
- Three nights at 110 €: 330 €. A simplified invoice is possible.
- Taxable base: 330 ÷ 1.10 = 300 €. VAT: 30 €.
- Five nights at 110 €: 550 €. It exceeds 400 €: full invoice.
- Taxable base: 550 ÷ 1.10 = 500 €. VAT: 50 €.
The full invoice under article 6 requires the recipient's name and address, the base, the rate and the VAT shown separately. For the German guest who asked for it, that means recording his identification details in the booking. The simplified invoice under article 7 carries fewer details, but if the recipient is a business, or a private individual who needs it for a tax right, and requires it, their tax number, their address and the VAT shown separately have to be added.
Royal Decree-law 26/2026 would have put stays of up to 30 nights at the 10 % rate from 1 December 2026, but Congress voted it down on 2 October 2026; the outer limit is now July 2028. Each invoice follows the rules in force on the date the VAT falls due, so when the measure arrives a booking paid in advance before its start will need a closer look: an advance payment can bring the charge forward. The detail is in the guide on the 10 % VAT on holiday lets.
Numbering, series and the last-minute cancellation
Each invoice carries a number and, where applicable, a series, consecutive within each series. The regulation requires separate series in two situations that affect Álvaro. Corrective invoices always go in their own series. And under article 7.1.a), if in the same year he issues full and simplified invoices, each kind has to go in its own series. A simple proposal: PALMA for the exempt flat, SM-C for the full invoices from Santa María, SM-S for the simplified ones and R for corrective invoices.
If a guest cancels after paying and part of the price is refunded, the invoice is not deleted, nor is another issued with the number of the first. A corrective invoice is issued that identifies the original and the detail that changes. Article 4.1.b) allows that corrective invoice to be issued as a simplified invoice.
To review how the invoicing for your flats is set up, you can send us one booking of each kind, the platform's payout statement and an invoice you have issued, if there is one, through the holiday let form.
The platform invoices its commission, not your accommodation
Airbnb or Booking collect from the guest and transfer the net amount, but their invoice is usually for their commission, addressed to the host. That is an invoice received by Álvaro, with its own VAT treatment, and it does not document the stay as far as the guest is concerned. If the platform is foreign, that commission usually has consequences for Modelo 303 and Modelo 349, which are explained in the guide on Modelo 349 and Airbnb commissions.
Nor does the lack of an invoice hide anything. The platforms report to Hacienda, as the Spanish tax office is commonly known, what each host earns: from the 2024 tax year on Modelo 238 (the EU DAC7 regime), which replaced the old Modelo 179, with the amounts collected. What an invoice contributes is order: it lets you match the gross amount of each booking against the commission and the net amount received, which is what is reviewed in what Airbnb reports to the tax office.
The invoicing software
Anyone who issues invoices with a computer program will have to use one that complies with the regulation on invoicing systems approved by Royal Decree 1007/2023, whose date of application has been changed more than once. Before signing up for a program, it is worth checking the date currently in force and that the provider declares compliance. For the exempt flat with few invoices a year, a simple and orderly system is enough; for the hotel-style one, the volume usually justifies something more.
What to keep
As well as the invoices issued, for each stay it is worth keeping the booking, the proof of payment, the platform's payout statement and, for the flat with services, proof of which services were provided. If one day Hacienda argues that the flat on Calle de la Palma provided hotel services, the defence will lie in those papers, not in the absence of invoices. The retention periods should cover, at the very least, the four years in which the tax authorities can carry out a review.
Invoicing is only one part of the taxation of a tourist let. The page on Salama Tax for tourist homes explains how VAT, the income tax return and the registration obligations fit together depending on whether you have one flat or several.