Doctrine by topic · DGT Observatory

Exchange of Invoices: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 11 rulings · 2014–2026

Current position

Invoices issued in substitution or exchange of simplified invoices do not qualify as corrective invoices, provided that the original complied with the requirements of article 7.1 of the Regulation. The period for requesting this exchange is four years from the accrual date, coinciding with the deduction period. The entrepreneur may choose the method of issuance, whether paper or electronic format, without the use of computer systems conditioning the form of issuing the substitution invoice.

The DGT's position remains constant regarding the legal nature of exchange invoices, which are not corrective. The doctrine has specified the management of these invoices, clarifying that they cannot be grouped into a single summary invoice if they belong to different periods. Recently, the freedom to choose the medium (paper or electronic) for these issuances has been confirmed.

Turning points

  1. V1409-17

    Clarifies that to substitute several simplified invoices from different periods, it is necessary to issue one invoice for each, prohibiting a single summary invoice.

  2. V3220-19

    Establishes that substitution invoices may be issued in electronic format with the recipient's consent and are not considered duplicates of the original.

Analysis based on 10 of 11 rulings with a stated position. Updated 28 September 2026.

Rulings on this topic

11
V0686-26 26 Mar 2026

Business owners can choose between paper or electronic invoices

SG de Impuestos sobre el Consumo
factura simplificadafactura electrónicasistema informático de facturaciónseries de facturascanje de facturas LIVA — Ley 37/1992 del IVA art. 4.1LIVA — Ley 37/1992 del IVA art. 5.1
Affects CompanyExpat · Non-residentIndividual

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