Normally, a business owner or self-employed professional issues their own invoices. In practice, however, there are business models in which the customer or a platform issues the invoice on behalf of the business owner.

This procedure is known as Self-Billing. Under Spanish invoicing regulations, this is referred to as the issuance of the invoice by the “destinatario de la operación” (recipient of the transaction).

But is Self-Billing permitted in Spain – and what happens to the sequential invoice numbering?

What does Self-Billing mean?

Under a Self-Billing arrangement, the recipient of the supply issues the invoice in the name and on behalf of the business that supplied the goods or services.

Spanish invoicing regulations expressly permit this procedure. Under Article 5 of Royal Decree 1619/2012, this requires, in particular, a prior agreement between the parties and a procedure for accepting the invoices issued.

It is important to note:

Even if the customer technically prepares the invoice, it remains an invoice of the business that supplied the goods or services.

What happens to the sequential invoice numbering?

As a general rule, invoices must be numbered sequentially within the same invoice series.

However, there is an important exception for Self-Billing:

Invoices issued by the recipient of the supply or by a third party must be kept in a separate invoice series. A separate series must be used for each person or entity issuing the invoices.

A Self-Billing invoice therefore does not have to be incorporated into the business owner's normal invoice numbering series.

For example, the following may exist in parallel:

• own invoices: 2026-001, 2026-002, 2026-003 …
• Self-Billing invoices issued by one platform: separate series
• Self-Billing invoices issued by another platform: separate series

Do I need to issue an additional invoice myself?

If a Self-Billing procedure has been properly established, generally no.

The invoice has already been issued in the name and on behalf of the business owner. An additional invoice for the same transaction is therefore generally not required.

Instead, the Self-Billing invoice must be recorded in the accounts and retained as the corresponding sales invoice of the business.

It must also contain all the information legally required on an invoice. In addition, where the invoice is issued by the recipient of the supply, the wording “facturación por el destinatario” (“self-billing”) is required.

Particularly when dealing with platforms, it should therefore be checked whether the document provided is actually an invoice or merely a statement or payment summary.

Self-Billing and Reverse Charge are not the same

The two concepts address different questions:

Self-Billing: Who issues the invoice?
Reverse Charge: Who is liable for VAT?

Both mechanisms can apply to the same invoice. Whether the Reverse Charge mechanism applies must be assessed independently of Self-Billing on the basis of the specific transaction and the businesses involved. Where the Reverse Charge mechanism applies, the wording “inversión del sujeto pasivo” (“reverse charge”) must generally be included.

A practical example is Amazon KDP: for certain EU publishers, Amazon offers a Self-Billing procedure under which Amazon issues invoices on behalf of the publisher. Here too, it is essential to determine whether a properly issued Self-Billing invoice exists and whether the VAT treatment is correct.

 

What changes with e-invoicing in Spain?

Spain's new B2B e-invoicing system also expressly takes into account cases in which invoices are issued by the recipient of the supply or by a third party. Self-Billing therefore remains possible in principle.

However, particularly in international business relationships, it must be determined whether the specific invoice actually falls within the scope of Spain's mandatory e-invoicing rules. Relevant factors include, among other things, where the business receiving the supply is established and to which permanent establishment the transaction is attributable.

Details regarding the implementation, scope and deadlines are explained in our separate article on e-invoicing in Spain.

Conclusion

Self-Billing is generally permitted in Spain. Subject to the applicable legal requirements, a customer or platform may issue an invoice in the name of the business owner.

Particularly important: Self-Billing invoices must be kept in a separate invoice series. They therefore do not have to be incorporated into the business owner's normal sequential invoice numbering.

An additional invoice issued by the business owner for the same transaction is generally not required. The decisive factors are that the Self-Billing arrangement has been properly agreed, that the invoice contains all the required information and that the tax treatment is correct.

Our law and tax firm will be pleased to assist you in analysing your specific situation, handling the necessary administrative procedures on your behalf and preparing and filing the relevant tax returns. If you are interested in our services or have specific questions on this subject, please feel free to contact us by email or telephone.

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Author:

Lisa Wörfel
Tax Advisor
info@sspartners.es
Tel: (+34) 951 12 13 06
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