Invoice issuance deadlines: validity of the date between accrual and the 15th day

Billing management is a critical aspect of the daily operations of any company. A recurring question among professionals is whether the issuance date of an invoice must strictly coincide with the moment of accrual or if there is a time margin permitted by current regulations.

What the DGT has resolved

The Directorate General of Taxes (DGT) has clarified that, when the recipient of the operation is an entrepreneur or professional, invoices may be issued from the moment the accrual occurs until the 15th day of the following month. In the case analyzed, after the accrual occurred on June 3, the issuance of the invoice on the 12th of that same month is considered correct and in accordance with the law.

Furthermore, the inquiry addressed the relationship between the issuance date and commercially agreed payment terms. In this regard, the DGT has indicated that it does not have the competence to provide information on the payment terms of commercial operations, as this is not a matter of a tax nature, but rather an agreement between parties.

What it means for you

This criterion confirms the legal certainty of billing deadlines within the scope of Value Added Tax (IVA). For companies, this implies that:

• The invoice date does not necessarily have to be the exact date of the operation's accrual.
• There is a legal margin to issue the document during the month following the accrual, provided that the 15th day is not exceeded.
• The validity of the invoice for tax purposes is maintained if this period is respected.

What you should do

It is necessary to distinguish between the tax obligation to issue the invoice and commercial payment agreements. While the regulations of Law 37/1992 and RD 1619/2012 regulate issuance deadlines, payment terms are a contractual matter. It is recommended to ensure that internal billing processes respect the limit of the 15th day of the following month to guarantee compliance with IVA regulations and avoid discrepancies with clients.