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V0650-26 20 March 2026 · SG de Tributos Criterion in force
IRPF · obligaciones tributarias formales

Pharmacies excluded from RSIF if billing delegated to third party

A consulting entity asks whether pharmacies delegating invoice issuance via their marketplace platform must comply with the new digital invoicing regulation (RSIF). The DGT responds that such operations may be excluded from RSIF if delegation and accounting records requirements are met.

The question raised

Question raised

The DGT's ruling

Pharmacy offices, being taxpayers of Personal Income Tax (IRPF) with economic activity, are subject to the Simplified Regime for Invoicing (RSIF). However, operations materially invoiced by a third party are excluded from the objective scope of the RSIF if the requirements of Article 5 of the ROF are met and the registration books are maintained according to Article 62.6 of the VAT Regulations. The delegation of invoicing does not exempt the taxpayer from their responsibility regarding compliance with the obligations of both regulations.

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