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V1929-18 29 June 2018 · SG de Impuestos sobre el Consumo Criterion in force
IVA · régimen especial de agencias de viajes

Retail agencies may only invoice end customers if they meet the requirements of the fourth additional provision of the Billing Regulations

A query was raised regarding how retail agencies should invoice travel packages arranged by wholesalers (in the Canary Islands or within the scope of VAT) when acting on their behalf and for their account. The DGT clarifies that the retailer does not provide the travel service to the customer, but rather a mediation service to the wholesaler, and may only invoice the traveller under specific conditions set out in the Billing Regulations.

The question raised

When retail agencies sell trips organized by wholesale agencies established in the Canary Islands and in the territory of application of Value Added Tax, acting on behalf and for the account of the latter, the question arises regarding the manner in which the operations performed must be invoiced.

The DGT's ruling

The retail agency acting on behalf and for the account of another provides a mediation service to the wholesaler, rather than a travel service to the end customer. As a general rule, the retailer does not invoice the travelers, as the obligation lies with the taxable persons providing the travel services. The retailer may only issue an invoice to the customer if the requirements of the fourth additional provision of the Billing Regulations are met, such as the request of the recipient and the nature of the services (transport, hospitality, etc.), and must use a separate series and comply with specific information requirements.

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