Frequently asked questions (FAQ)

There are 2 types of affected groups:

1. The producers and marketers of computerized billing systems (SIF) in matters relating to their respective production and marketing activities of computer systems intended to be used by the group mentioned below in the following section.

2. Those businessmen and professionals – natural or legal persons – who, being established in Spanish territory, issue invoices (see explanatory NOTE 1 at the end of this answer), provided that they comply with the following 4 conditions (what could be called the “rule of the 4 “NOs””):

   1. That DO NOT invoice exclusively manually (without the help of SIF). In other words, they use some SIF to issue invoices.

   2. That NOT are subscribed, either mandatorily or voluntarily, to the requirements of the so-called Immediate Supply of Information or SII. See explanatory NOTE 2 at the end of this answer.

   3. That NOT have their tax domicile in the Historical Territories of the Autonomous Community of the Basque Country or the Foral Community of Navarra. See further clarification in NOTE 3 at the end of this answer.

   4. That DOES NOT have any non-application resolution in force that exempts them from complying with the RRSIF, approved by Royal Decree 1007/2023, of December 5. See explanatory NOTE 4 at the end of this answer.

NOTE 1 to section 2 of this answer :

As can be seen, in this second section, reference is made at all times to those who issue INVOICES – including simplified invoices – whatever the reason for doing so (normally because they are required to do so under Royal Decree 1619/2012, of November 30, which approves the Regulation governing billing obligations, ROF). Thus, in this regard, all those operations that are not documented with an invoice are excluded because there is no obligation to issue an invoice according to said RD 1619/2012 and ROF (including the "special" authorizations granted that may exist in this regard).

Therefore, whether or not an invoice is issued is key because, by definition (article 1.2 of the RRSIF), the RRSIF does not change the substantial billing obligations. A SIF –whose operation is regulated by the regulations– is, in essence, a computer system used to issue INVOICES. So the RRSIF does not apply to computer systems that do not issue invoices.

NOTE 2 to letter b) of section 2 of this answer :

The SII refers to the maintenance of VAT record books in the electronic headquarters of the Tax Agency in accordance with the terms established in section 6 of article 62 of the Value Added Tax Regulations, approved by Royal Decree 1624/1992, of December 29.

If a taxpayer is covered by the SII, he/she must use a System that allows him/her to comply with the SII's information requirements.

NOTE 3 to letter c) of section 2 of this answer :

Letter c) of section 2 refers to the fact that the tax levying authority based on the domicile of the person issuing the invoice is NOT specific to the Historical Territories of the Autonomous Community of the Basque Country or the Foral Community of Navarre, in accordance with the rules of the Economic Agreement and Convention. That is, those who carry out economic activities (whether they are individuals or legal entities) that are subject to the local regulations on Direct Taxation due to said activities are NOT taxable persons, both in the case of the 3 historical territories of the Autonomous Community of the Basque Country (Law 12/2002, of May 23, approving the Economic Agreement with the Autonomous Community of the Basque Country, and, specifically, as established in articles 6 and 14 of said text, respectively, for Personal Income Tax and Corporate Tax), as in the case of the Foral Community of Navarre (Law 28/1990, of December 26, approving the Economic Agreement between the State and the Foral Community of Navarre, and, specifically, as established in articles 9 and 18 of said text, respectively, for Personal Income Tax and Corporate Tax). In accordance with the aforementioned existing regulations on this matter and according to the application conditions given in the RRSIF, this circumstance is determined based on the tax domicile of the same.

Finally, to avoid any doubts regarding this aspect, it is confirmed that those obliged to issue invoices based in the Canary Islands, Ceuta or Melilla are subject to the application of the regulation (at least as regards this criterion), understanding that the references to the Value Added Tax (VAT) should be considered to be made to the Canary Islands General Indirect Tax (IGIC) and the Tax on Production, Services and Importation (IPSI), respectively.

NOTE 4 to letter d) of section 2 of this answer :

It refers to the possibility specifically provided for in Article 5 of the RRSIF.

Regulations/Doctrine:

• Article 2.j) of Law 58/2003, of December 17, General Tax (LGT).

• Articles 1, 3, 4 and 5 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals (RRSIF), and the standardization of formats of billing records, approved by Royal Decree 1007/2023, of December 5.

• Royal Decree 1619/2012, of November 30, approving the regulations governing billing obligations (ROF).

• Article 62.6 of the Value Added Tax Regulations, approved by Royal Decree 1624/1992, of December 29.

This varies depending on the affected group (see FAQ "Who is affected by the regulation establishing the requirements for computerized billing systems?" in General questions: areas of application ) in question:

1. Business owners and professionals who issue invoices and are affected by the regulation must have their computerized billing systems (SIF) operational, adapted to the characteristics and requirements established in it and in its implementing regulations, before July 1, 2025.

2. Producers and marketers of those SIFs to which the regulation applies, in relation to their production and marketing activities of said SIFs, must offer their products fully adapted to the regulation within a maximum period of nine months from the entry into force of the ministerial order that develops the technical specifications of the requirements imposed on the SIFs. However, in relation to SIFs included in multi-annual maintenance contracts contracted before this last deadline, they must be adapted to the content of the regulation before July 1, 2025.

Naturally, if those obliged have SIFs adapted prior to these deadlines, they may begin to use them and the Tax Agency will have the means to facilitate, where appropriate, the submission of billing records for the SIFs "VERI*FACTU" prior to said date.

Regulations/Doctrine:

• Fourth Final Provision of Royal Decree 1007/2023, of December 5, approving the regulations establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF).

No, as long as no invoices are issued or they are ALL issued by hand, that is, without using a computerized billing system (SIF).

On the other hand, if at any time an invoice were issued – for whatever reason – and a SIF were used for this, then the RRSIF would be applicable (provided that the rest of the conditions indicated in section 2 of the frequently asked question "Who is affected by the regulation that establishes the requirements for computerized billing systems?" (rule of the 4 "NOs") of General questions: areas of application .

It is important to remember that the RRSIF only applies to SIFs and these, by definition (article 1.2 of the RRSIF), are only considered as such if they are used to issue what –according to the ROF– is considered an INVOICE, including the simplified invoice (article 1.2 of the RRSIF) but not other similar or “equivalent” documents that also justify operations.

Regulations/Doctrine:

• Article 2.j) of Law 58/2003, of December 17, General Tax (LGT).

• Articles 1, 3, 4 and 5 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

• Royal Decree 1619/2012, of November 30, approving the regulations governing billing obligations (ROF).

The subjective scope of the SIF Regulation approved by RD 1007/2023 does not include those persons who carry out economic activities (whether natural or legal persons) who are subject to the regional regulations on direct taxation due to said activities.

To determine which entrepreneurs and professionals are subject to regional regulations, the rules of Law 12/2002, of May 23, approving the Economic Agreement with the Autonomous Community of the Basque Country, will be followed, and, specifically, the provisions of articles 6 and 14 of said text, respectively, for Personal Income Tax and Corporate Tax.

In the historical territories of Guipúzcoa, Vizcaya and Álava, a system known as “TicketBAI” is being applied in its different content modalities similar to the VERI*FACTU modality of the Regulation of Computerized Billing Systems.

For example, in the event that a company with a registered office in the province and another with a registered office in common territory (rest of Spain) have a commercial relationship, the SIFs used by the former to issue its invoices will be subject to the obligations established by its corresponding Provincial Treasury, while the SIFs of the latter would be subject to the RRSIF.

Regulations/Doctrine:

• Article 1.3 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

As a general rule, in the Foral Community of Navarra, RD 1007/2023, of December 5, which approves the Regulation governing computer billing systems, will not be applicable when entrepreneurs and professionals are subject to foral regulations in accordance with the rules of Law 28/1990, of December 26, which approves the Economic Agreement between the State and the Foral Community of Navarra, and, specifically, in accordance with the provisions of articles 9 and 18 of said text, respectively, for Personal Income Tax and Corporate Tax.

Yes, taxpayers with tax domicile in the Canary Islands, Ceuta and Melilla are included within the subjective scope of application of the SIF Regulation approved by Royal Decree 1007/2023 and, consequently, said regulations and those developed by Ministerial Order apply to them.

In accordance with article 1.3, the references made by the SIF Regulation to the regulations on Value Added Tax will also be considered to be made to the regulations on the Canary Islands General Indirect Tax and to the Tax on Production, Services and Importation in Ceuta and Melilla.

Yes, provided that you also meet the other conditions indicated in section 2 of the FAQ "Who is affected by the regulation establishing the requirements for computerized billing systems?" (rule of the 4 "NOs") of General questions: areas of application .

Royal Decree 1007/2023, of December 5, and the regulations on requirements for computer billing systems (RRSIF) that it approves are applicable throughout non-regional Spanish territory, taking into account the specialties provided for in its specific regulations for the Canary Islands, Ceuta and Melilla, understanding that the references made to the regulations of the Value Added Tax (VAT) must also be considered to be made to the regulations of the Canary Islands General Indirect Tax (IGIC) and the Tax on Production, Services and Importation (IPSI), respectively.

Regulations/Doctrine:

• Article 1.3 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

Article 3 of the SIF Regulation, approved by Royal Decree 1007/2023, specifies the subjective scope of the regulations by referring it to taxpayers of Corporate Tax (i.e. entities and commercial companies), of Personal Income Tax that carry out economic activities and of IRNR that carry out their activity through a Permanent Establishment - which will apply the Corporate Tax regulations with specialities -, as well as entities under an income attribution regime that carry out economic activities.

In order to answer the question, it is necessary to first determine whether the rental of homes or premises is carried out through a legal entity (in which case it falls within the scope of letter a) of the aforementioned article 3) and whether the leasing of real estate is considered an economic activity for the purposes of personal income tax (in which case it would fall within the scope of letter b) of the aforementioned article 3). Therefore, as regards personal income tax, it is necessary to determine whether the lease carried out involves the performance of economic activity or, on the contrary, is a source of income from real estate capital. To be considered an economic activity, self-management of human and material resources is required, including the existence of dedicated premises and hired personnel. Otherwise the leasing activity would not be business-related.

Therefore, if the activity is not considered a business activity, it will not be an economic activity within the meaning of article 3.1.b) RRSIF, and in that case the lessor will not have to adapt because no economic activity is being carried out.

Regulations/Doctrine:

• Article 3.1 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

These are different regulations with different obligations. The SII consists of keeping VAT record books (invoices issued, invoices received, investment goods, etc.) through the electronic headquarters of the Tax Agency, which implies obligations to electronically communicate to the Tax Agency a wide range of information related to the VAT of invoices issued and received within a certain period of time. For its part, the regulation that establishes the requirements for computerized billing systems requires SIFs to record, with certain security and control measures, certain information only on invoices issued, which may optionally be sent to the Tax Agency.

The subjective scope of both projects is exclusive, that is, those who comply with the SII do not have to comply with the regulations that establish the requirements for computerized billing systems and vice versa.

Therefore, in accordance with article 3.3 of the Regulation approved by RD 1007/2023, this Regulation does NOT oblige taxpayers subject to the Immediate Supply of Information (SII) in relation to their own invoices.

Regulations/Doctrine:

• Article 3.3 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

• Order HFP/417/2017, of May 12, regulating the normative and technical specifications that develop the maintenance of the Value Added Tax registration books through the electronic headquarters of the State Tax Administration Agency established in article 62.6 of the Value Added Tax Regulations, approved by Royal Decree 1624/1992, of December 29, and other tax regulations are modified.

Yes, through the option provided for in the census declaration model 036, a taxpayer who has registered with REDEME or who has directly voluntarily opted for the SII would not be obliged to comply with the specifications of RD 1007/2023, without prejudice to assuming from the immediately following settlement period all the obligations arising from article 62.6 of the RIVA on its issued and received invoices.

Regulations/Doctrine:

• Article 3.3 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

Not in general, since those subject to this regime are not required to issue an invoice except in certain exceptions.

However, the answer is the opposite, provided that they use a computerized billing system, when they issue other mandatory invoices for the delivery of real estate referred to in the second paragraph of section one of article 129 of Law 37/1992, of December 28, on Value Added Tax, as indicated in the last paragraph of article 3.3 of the ROF, and provided that they also comply with the rest of the conditions indicated in section 2 of the frequently asked question "Who is affected by the regulation that establishes the requirements for computerized billing systems?" (rule of the 4 "NOs") of General questions: areas of application . For these exceptional operations, they may use the system provided for this purpose by the AEAT in its electronic headquarters, in accordance with article 7.b) of the RRSIF.

Regulations/Doctrine:

• Article 4.1 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

• Articles 3.3 and 16.1 of the regulations governing billing obligations (ROF), approved by Royal Decree 1619/2012, of November 30.

• Article 129.1 of Law 37/1992, of December 28, on Value Added Tax.

Not in general, since those subject to this regime are not required to issue an invoice, except in certain exceptions.

Article 4.2 of the regulation on requirements for computer billing systems (RRSIF), approved by Royal Decree 1007/2023, of December 5, establishes that said regulation does not apply to the operations referred to in letters b), c) and d) of article 3.1 of the regulation governing billing obligations (ROF), approved by Royal Decree 1619/2012, of November 30, for which there is no obligation to issue an invoice.

Therefore, as a general rule, if you only carry out operations in equivalence surcharge, the obligations derived from the RRSIF will not apply to you.

However, you must comply with the obligations of the regulation that establishes the requirements for computerized billing systems if you issue invoices, provided that you also comply with the other conditions indicated (“rule of the 4 “NOs””). According to the billing regulations, under the equivalence surcharge regime, invoices must be issued for carrying out certain operations:

• When you make deliveries of properties subject to and not exempt from VAT.

• When paying taxes in IROF by direct assessment.

• When the client is a businessman or professional or a Public Administration.

• When the recipient requires it to exercise any right of a tax nature.

• When required for certain foreign trade operations.

For these exceptional operations, they may use the system provided for this purpose by the AEAT in its electronic headquarters, in accordance with article 7.b) of the RRSIF.

Regulations/Doctrine:

• Article 4.2 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

• Article 3.1.b) of the regulations governing billing obligations (ROF), approved by Royal Decree 1619/2012, of November 30.

Not in general, since those subject to this regime are not required to issue an invoice, except in certain exceptions.

Article 4.2 of the Regulation on Requirements for Computer Billing Systems (RRSIF), approved by Royal Decree 1007/2023, of December 5, establishes that said regulation does not apply to the operations referred to in letters b), c) and d) of article 3.1 of the regulation governing billing obligations (ROF), approved by Royal Decree 1619/2012, of November 30, for which there is no obligation to issue an invoice.

Therefore, as a general rule, if you only carry out operations under the simplified VAT regime, the obligations derived from the RRSIF will not apply to you.

However, you must comply with the RRSIF obligations if you issue invoices, provided that you also comply with the other conditions indicated (“rule of the 4 “NOs””). According to the invoicing regulations, under the simplified VAT regime, invoices must be issued for carrying out certain operations:

• When the determination of the accrued quotas is made based on the volume of income,

• When making the sale of fixed assets,

• When the client is a businessman or professional or a Public Administration.

• When the recipient requires it to exercise any right of a tax nature.

• When required for certain foreign trade operations.

For these exceptional operations, they may use the system provided for this purpose by the AEAT in its electronic headquarters, in accordance with article 7.b) of the RRSIF.

For more details, please consult

Regulations/Doctrine:

• Article 4.2 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

• Article 3.1.c) of the regulations governing billing obligations (ROF), approved by Royal Decree 1619/2012, of November 30.

• Article 123.One.B).3.º of Law 37/1992, of December 28, on Value Added Tax.

Simplified invoices are subject to the RRSIF and, in the case of VERI*FACTU systems, must be communicated to the AEAT. The above is independent of whether an invoice or summary extract is generated at the end of the day, with the purpose of recording the day's sales in a single accounting entry or managing the business.

In the case of operations corresponding to special VAT regimes, simplified, equivalence surcharge or agriculture, we refer to the questions specifically dedicated to these.

Regulations/Doctrine:

• Article 2 of the regulation that establishes the requirements that must be adopted by the computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5

Yes, the conventional or virtual form through which goods are offered or delivered or services are provided is irrelevant for the mandatory application of the regulations included in the regulation of requirements for computerized billing systems (RRSIF), approved by Royal Decree 1007/2023, of December 5, and its implementing regulations.

Online sales, in some cases, have specific regulations when using European one-stop shop regimes, which may give rise to specific coding in the billing registration register, but such specialities do not exclude compliance with the obligations of the RRSIF.

Regulations/Doctrine:

• Articles 2 and 3 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

In the event that billing is done manually, using checkbooks or by writing on them by hand or typewriter, it would not be affected by the RRSIF because it does not use ANY computerized billing system (SIF) to issue its invoices.

A simple and suitable alternative that can serve to replace manual systems is to use the basic invoicing application that the Tax Agency will offer free of charge on its electronic site, as long as its functionalities and conditions of use are adjusted to the needs of whoever is going to use it.

On the other hand, if spreadsheets or processors are used, it is not possible to answer without having exact knowledge of the system, since both have data storage and processing utilities, which would make them Billing Computer Systems.

Regulations/Doctrine:

• Article 2.j) of Law 58/2003, of December 17, General Tax Law.

• Article 1 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

No, if in accordance with the Regulation governing billing obligations, approved by Royal Decree 1619/2012, of November 30, or by a billing authorization of article 3.1.d) of said same Regulation, there is no billing obligation, the regulations of the Billing Computer Systems Regulation will not be applicable either. 

The inclusion of the QR code and the mention VERI*FACTU is applicable to the computer systems referred to in article 7 of the Regulation approved by Royal Decree 1007/2023. Since those obligated to the SII are excluded from this subjective scope, these requirements ONLY apply to the operations and those obligated under Article 3. Those required to submit to the SII, for all purposes, are not affected by RD 1007/2023.

Regulations/Doctrine:

• Article 3.3 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

• Section 5 of Article 6 and Section 5 of Article 7 of the Regulation governing billing obligations, approved by Royal Decree 1619/2012 of 30 November.

Yes, in fact, all the obligations of Royal Decree 1007/2023, as regards users, will apply on the proposed date, since the modified regulations of the Billing Obligations Regulation (ROF) RD 1619/2012, depend on those regulated in the regulation that establishes the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF).

The obligations for producers and marketers (to produce and sell adapted software programs) will come into force 9 months after the publication of the technical OM.

Naturally, if those obliged have previously adapted systems, they will be able to start using them and the Agency will have the means to facilitate the sending of VERI*FACTU in advance.

Regulations/Doctrine:

• Fourth Final Provision of Royal Decree 1007/2023, of December 5, approving the regulations establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF).

 No, these exclusions imply that the RRSIF will not apply to such operations.

However, it should be noted that even in the cases excluded from billing by article 3.1.a) ROF, there are exceptions indicated in article 2.2 of the ROF that require the issuance of an invoice. In such cases, the taxpayer must comply with the obligations of the regulation that establishes the requirements for computerized billing systems in the event that it issues invoices, provided that it also complies with the rest of the conditions indicated (“rule of the 4 “NOs””).

Regulations/Doctrine:

• Article 1.2 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

• Articles 3.1.a), 3.2 and 2.2 of the Regulation governing billing obligations, approved by Royal Decree 1619/2012, of November 30.

The regulations consider taxpayers individually (not by groups) with regard to their billing obligations, so that, even if they belong to the same group of companies, they must comply with their billing obligations according to their status. Therefore, the SIF of each company must comply with the billing obligations that correspond to it. It should be noted, however, that entities within a group may voluntarily register with the SII in order to maintain management consistency with the group to which they belong.

On the other hand, there are market products capable of applying the requirements of both regulations.

Regulations/Doctrine: 

Article 3 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

In the event that the sole proprietor is obliged to issue an invoice (ordinary or simplified), from the moment that he uses a computerized billing system consisting of a cash register to record the sales made and print for each of them what should be a simplified invoice to deliver to the client, he is subject to RD 1007/2023, of December 5, and the regulations approved by it, so he must comply with it, either by adapting the cash registers (if this were possible), or by acquiring an adapted computerized billing system (SIF).

As for the electronic scale, if the businessman or professional uses it only to weigh the product and obtain the amount that is then manually entered into the cash register to issue the final simplified invoice, it would not be considered a SIF, but rather an -independent- auxiliary element for measurement (and, where appropriate, for calculating the amount associated with the product, according to its price per kilogram). In this case, the SIF would be the cash register, so the electronic scale would not have to adapt to RD 1007/2023.

However, there are electronic scales with more powerful features that allow the accumulation of the amounts of the different products weighed and issue a simplified invoice for the total purchase made in a single act (among other possible features), so they would then be considered SIF as they are also used as cash registers. In other words, they would be SIF with other auxiliary electronic elements (in this case, for weighing) added. If so, then they should adapt to RD 1007/2023 and the regulations approved by it. Internet connections can be managed through telephone lines, and non-verifiable invoice issuing systems allow files to be kept at the local headquarters.

Regulations/Doctrine: 

• Article 3 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

Yes, ALL operations for which entrepreneurs and professionals (natural or legal persons) must issue an invoice in accordance with current regulations (especially in accordance with the Billing Obligations Regulation approved by RD 1619/2012) are subject to the RRSIF. This includes both exports and intra-Community deliveries of goods and international or intra-Community supplies of services.

Regulations/Doctrine:

• Articles 1, 3 and 4 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.

Yes, when the non-resident entrepreneur has a permanent establishment for the purposes of the Non-Resident Income Tax regulations (Royal Legislative Decree 5/2004, of March 5).

Regulations/Doctrine:

• Article 1 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5.