The Spanish Directorate-General for Taxation has clarified two important issues regarding the application of VERI*FACTU: invoices issued to foreign clients may also be subject to this regulation, and invoicing software cannot include fictitious companies within its real production environment.
These clarifications come while companies continue preparing their invoicing software systems. Corporate Income Tax taxpayers must have their systems adapted before 1 January 2027. For all other obliged taxpayers, the deadline ends on 1 July 2027.
Does VERI*FACTU apply when invoicing foreign clients?
Issuing invoices to clients in other countries does not mean that a company is excluded from VERI*FACTU.
The Spanish Directorate-General for Taxation states that the key point is not where the client is resident, but who issues the invoice and which system is used to do so.
Therefore, if a company or professional is subject to the regulation and uses invoicing software, they must also comply with VERI*FACTU when invoicing clients in the European Union or in third countries.
This means that companies with international activity must ensure that their software correctly handles all their transactions, not only sales made to Spanish clients.
There are some excluded cases, such as certain transactions carried out through permanent establishments located abroad. For this reason, each case should be reviewed by considering how the activity is carried out.
Can fictitious companies be created to test the software?
The Spanish Directorate-General for Taxation has also addressed software systems that allow the creation of fictitious companies for simulations, technical testing or user training.
These test companies cannot be included in the production environment, meaning the software that is used to issue and manage invoices. This applies even if they do not carry out real transactions or generate invoices with tax effects.
Testing may still be carried out, but it must be kept in an independent environment that is clearly separate from the system used for real invoicing.
This clarification is especially relevant for software developers and providers. However, companies should also review with their provider how testing, training and production environments have been configured.
What should companies review before adapting their invoicing systems?
Before the obligation enters into force in Spain, it will be important to check:
- Whether all invoices, including those addressed to foreign clients, are generated through an adapted system.
- Whether the provider has issued the software statement of responsibility.
- Whether test environments are separated from the real invoicing system.
- Whether international transactions are correctly configured from a tax and technical perspective.
VERI*FACTU does not depend only on the client’s country. The obligation is mainly linked to the company issuing the invoice, the transactions it carries out and the invoicing software system it uses.
Does your company need to review whether its invoicing software meets the VERI*FACTU requirements in Spain? From LEIALTA’s accounting and tax department, we can help you analyse your invoicing processes and detect which adjustments should be made before 2027.
