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A retail agency inquired whether it could issue invoices under the fourth additional provision of the Billing Regulations for services provided by Canarian wholesalers. The DGT ruled that, as services from Canarian wholesalers are not subject to VAT, it is not possible to adopt this specific billing regime.
Question raised: Correction of the invoice issued by the consultant to the end customers, by virtue of the fourth additional provision of the Billing Regulations. Applicability of the same procedure if the wholesale agency were established in the territory to which the Tax applies.
Travel services provided by wholesale agencies in the Canary Islands are not subject to VAT, unless they have a permanent establishment in the territory to which the Tax applies. Therefore, it is not possible to apply the fourth additional provision of the Billing Regulations to document such services. If the wholesaler had a permanent establishment in the territory to which the Tax applies, the services would be subject to VAT and could indeed be invoiced by the consultant under said regime.
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