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A travel agency inquires regarding the invoicing of trips purchased from wholesalers and mediation commissions. The DGT clarifies that the special regime only applies if the agency acts on its own behalf, whereas mediation on behalf of others is subject to a different invoicing regime.
Question raised: Invoicing of the consulted operations.
The special regime for travel agencies applies when the entity acts on its own behalf with respect to travelers using third-party services. If it acts on behalf and for the account of the client, it provides a different mediation service that does not fall under said special regime. To determine whether one is acting on their own behalf, the agreements between the agency and the third party, the information in the documents, and who pays the consideration must be assessed. In the case of mediation on behalf of others, invoicing must comply with the provisions of the fourth additional provision of the Invoicing Regulations.
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