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Record Books: 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 8 rulings · 2014–2026

Current position

Taxpayers under the simplified direct estimation regime must maintain the record books required by the IRPF (Personal Income Tax) Regulations, although there is no obligation to file them with the Mercantile Registry. In the field of IVA (VAT), the obligation to maintain record books of issued or received invoices depends on the nature of the activity and the applied regime, as occurs with the equivalence surcharge where their maintenance is not necessary. For operations with platforms, the issuance must be carried out on behalf of the seller to avoid inclusion in the RSIF.

The DGT's position remains constant regarding the need to maintain record books according to the taxation regime and the applicable IVA regulations. No doctrinal changes are observed, but rather clarifications on specific cases such as the equivalence surcharge, platform activities, or the nature of the simplified direct estimation. The requirement for accounting to deduct quotas remains a requirement before inspections.

Turning points

  1. V0151-19

    Clarifies that, even if there is no obligation to issue invoices, it is necessary to maintain the record book of received invoices, even in exempt activities.

  2. V2138-21

    Establishes that under the equivalence surcharge regime, there is no obligation to maintain record books of issued or received invoices.

Analysis based on 7 of 8 rulings with a stated position. Updated 12 October 2026.

Rulings on this topic

7

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