Doctrine by topic · DGT Observatory

Issuance 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

Stable position High confidence 24 rulings · 2014–2026

Current position

The issuance of invoices must be carried out with a correlative numbering based on the date of issuance and not on the date of the transaction. In the case of advance payments, there is an obligation to issue an invoice for the proportional part received, at which point the tax accrual occurs. For the VAT (IVA) charge to be valid, the invoice must be delivered to the recipient within the year following the accrual.

The DGT's position remains stable regarding the general rules of issuance and numbering. The evolution is observed in the precision regarding specific moments of obligation, such as invoicing for advance payments or the need to deliver the invoice to maintain the right to charge the tax.

Turning points

  1. V0333-22

    Clarifies that the correlation of the numbering must be based on the date of issuance and not on the date of the documented transaction.

  2. V1834-23

    Establishes that the invoice must be issued and delivered within one year from the accrual for the VAT (IVA) charge to be valid.

  3. V1058-26

    Determines the obligation to issue an invoice upon receipt of advance payments, which trigger the tax accrual.

Analysis based on 23 of 24 rulings with a stated position. Updated 24 September 2026.

Rulings on this topic

23
V0333-22 21 Feb 2022

Invoice numbering must be consecutive based on the date of issue

SG de Impuestos sobre el Consumo
numeración correlativaexpedición de facturaempresario o profesionalobligaciones de facturaciónseries 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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