How the DGT's position has evolved
Current position
For a document to be considered an invoice and allow for deduction, it must comply with the minimum content required by Articles 6 or 7 of the Invoicing Regulations. It is not mandatory for the document to include the specific designation of 'invoice' or 'simplified invoice'. However, documents with designations such as 'proforma fee', 'informative note', or 'expense note' are not valid if they lack said legal requirements.
The DGT's position has remained constant from 2018 to 2024. All rulings agree that the validity of the document does not depend on its name, but rather on strict compliance with the minimum regulatory content to allow for deduction.
Analysis based on 18 of 18 rulings with a stated position. Updated 25 September 2026.