Companies must issue invoices with their actual issuance date to avoid credit notes

Billing management is a critical process for the legal certainty of any economic activity. A common error consists of recording invoice dates that do not coincide with the actual moment the document is made available to the client, a practice that the Directorate General of Taxes (DGT) has recently clarified.

What the DGT has resolved

The DGT has determined that the issuance date of an invoice is, strictly speaking, the date on which said issuance occurs. Recording a date different from the actual one obliges the company to issue a credit note to correct the error.

Regarding the deadlines, the regulations establish the following:

• For entrepreneurs or professionals: If the recipient holds this status, invoices must be issued before the 16th day of the month following the accrual of the tax.
• Moment of accrual: In the delivery of goods, the accrual occurs when the product is made available to the acquirer.
• Issuance margin: The invoice can be issued from the date of accrual until the 15th day of the following month.

What it means for you

For companies, this criterion implies that it is not possible to use the date of product delivery or a date prior to the actual emission as the invoice date if it does not coincide with the act of issuance. Failure to comply with this technical precision entails the obligation to issue credit notes, which increases the administrative burden and the risk of errors in VAT accounting.

What should be done

It is necessary to ensure that billing systems and internal company processes guarantee that the date printed on the document is the effective date of its issuance. It must be monitored that, in operations with other entrepreneurs, issuance is always completed before the 16th day of the month following the accrual to comply with the legal deadlines established in the Invoicing Regulations and the VAT Law.