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V0878-24 23 April 2024 · SG de Impuestos Especiales y de Tributos sobre el Comercio Exterior y sobre el Medio Ambiente Criterion in force
OTRO · impuesto especial sobre envases de plástico no reutilizables

Separate charging of packaging tax cannot be avoided via self-invoicing

A paint manufacturer that produces its own plastic packaging inquired whether it could self-charge the tax through self-invoicing to avoid detailing it on sales invoices. The DGT ruled that this is not possible and that all invoicing obligations under the Law must be met.

The question raised

Possibility of self-assessing the IEEPNR through self-invoicing, thereby avoiding the specific and separate passing on of the tax to customers in the sales invoices for packaged paint.

The DGT's ruling

Upon the first delivery of the packaging following its manufacture, the manufacturer must pass on the accrued tax to the purchaser. The invoice must separately state the amount of the tax levies and the quantity of non-recycled plastic in kilograms. Failure to include these statements constitutes a tax infringement punishable by a fine of 75 euros per invoice.

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