Psychologists exempt from VAT must issue invoices for their sessions

The exemption from Value Added Tax (IVA) on psychological assistance services does not imply a waiver of formal invoicing obligations. Although healthcare activity is exempt from this tax, the professional maintains the duty to document their operations in accordance with current regulations.

What the DGT has ruled

The Dirección General de Tributos (DGT) has determined that professionals providing psychological assistance services, covered by the healthcare exemption provided for in Article 20.One.3º of Law 37/1992, must issue an invoice for their services. The tax exemption does not eliminate the obligation to issue the document certifying the provision of the service.

Furthermore, the ruling addresses two key operational aspects:

• Simplified invoice: Since the amount of each session is less than 400 euros, the professional has the option to fulfill their obligation by issuing simplified invoices.
• Online services: Services provided through direct online communication are not considered services provided by electronic means, as there is direct human intervention in the process.

What it means for you

If you are a self-employed professional providing healthcare services exempt from IVA, you cannot omit the issuance of invoices under the premise that the tax is not accrued. The obligation to invoice is independent of the tax burden of the operation.

For those professionals operating remotely, the nature of their service remains a traditional provision of services with human intervention, which prevents the application of specific rules for services provided by electronic means. Additionally, if your income per session is low, the regulations allow you to streamline document management by using the simplified invoice format.

What should be done

It is necessary to ensure that all services provided are duly documented. If you use simplified invoices, you must verify that you comply with the requirements of the Invoicing Regulations. It is fundamental to maintain an orderly record of these issuances to comply with the regulations for the management of healthcare professions and the IVA Law. It is recommended to assess the particular situation of each professional activity to guarantee compliance with formal obligations.