The Booking.com, Airbnb or Expedia commission invoice in Spain: VAT reverse charge, modelo 303 and modelo 349 and ROI registration (2026)

Updated: 10 November 2026

Every month the commission invoice from Booking.com, Airbnb or Expedia arrives, often without VAT and with a line about the «reverse charge». What do you have to do with it? We read the Spanish VAT Act (BOE) and the Spanish Tax Agency's pages (links at the end). Where we could not confirm something, we say so. This is not tax advice: check with your adviser.

The general rule

Spanish VAT Act (Ley 37/1992) and the Tax Agency's «Services» page:

A service supplied to a business established in Spain is treated as supplied in Spain (art. 69.Uno.1.º).
If the supplier is not established in Spain, the customer is liable for the VAT (art. 84.Uno.2.º a): this is the reverse charge.
In the Tax Agency's words: the VAT is settled by the customer.
In practice: the invoice arrives without VAT; you calculate it, declare it as output VAT and, if you meet the conditions, deduct it.

Where to declare it

Modelo 303: the Tax Agency says self-assessed VAT is generally declared in the 303.
Deduction depends on articles 92 onwards of the VAT Act. We have not read them: ask your adviser whether you can deduct it.
Modelo 349: if the supplier is in another Member State, it is an intra-EU acquisition of services that must also be reported in modelo 349.
In modelo 349 you use key I: intra-EU acquisitions of services located in Spain supplied by businesses from other Member States.
Modelo 349 is monthly or, if you do not exceed 50,000 euros in the quarter or the previous four, quarterly, within the first 20 days of the following month.
We have not checked the box numbers in the 303: your adviser or the Tax Agency's software will show them.

EU VAT number and ROI registration

Official Tax Agency page «ROI, VIES, NIF-IVA»:

You must obtain an EU VAT number (NIF-IVA) and register in the Intra-Community Operators Register (ROI) if you receive services from non-established businesses for which you are liable for the VAT.
You apply with modelo 036 (box 582 and the expected date of the first transaction in box 584).
With an EU VAT number, the platform can check it in VIES.

The exception to look at

Art. 84.Uno.2.º a) has exceptions. Two of them, in Spanish, verbatim:

d') «prestaciones de servicios de arrendamientos de bienes inmuebles que estén sujetas y no exentas» (taxable, non-exempt property rentals).
e') «prestaciones de servicios de intermediación en el arrendamiento de bienes inmuebles» (intermediation in property rentals).
In those cases there is no reverse charge: the non-established supplier would be the one declaring Spanish VAT.
Since 1 January 2023 (Ley 31/2022), the Tax Agency's 2023 VAT practical manual sums it up: services of intermediation in the rental of property supplied by businesses not established in Spain are excluded from the reverse charge. This exclusion does not require the rental to be taxable and non-exempt.
Holiday let without hotel-type services: the platform commission is intermediation in the rental of a property located in Spain, so there is no reverse charge: the platform must charge you Spanish VAT. Ruling V3292-23 of the Directorate General for Taxes (26-12-2023) applies «el tipo general del 21 por ciento» (the standard 21 % rate) to that intermediation. Ruling V0106-22 (24-01-2022) said the opposite (reverse charge), but it predates the 2023 change.
Hotel or holiday let with hotel-type services: we have not confirmed whether hotel accommodation counts as «rental of property» for this exception. Check with your adviser what your invoice says and why.

Holiday let without a business activity

What we confirmed:

The VAT Act (art. 5.Uno.c) says that lessors of property are «in particular» businesses. Anyone who rents out a home for money is a business for VAT purposes, even if the rental is exempt.
According to the Tax Agency, renting tourist apartments is VAT-exempt without hotel-type services and taxed at 10 % with them.
If the rental is exempt, since 2023 you do not self-assess the commission of a non-established platform: the platform must charge you Spanish VAT (21 %) on the invoice (exception e') of art. 84.Uno.2.º a), the Tax Agency's 2023 VAT manual and ruling V3292-23). Since you only make exempt supplies, you cannot deduct that VAT.
If your commission invoice arrives without VAT and with a reverse-charge note, ask your adviser and the platform why.

Does the platform charge Spanish VAT?

We have not confirmed in an official source which company invoices you (Booking.com B.V., Airbnb Ireland, an Expedia entity or another) or whether any of them charges Spanish VAT.
Look at your invoice: issuer name and country, its VAT number and whether it shows VAT or a reverse-charge note.
Spain's Ley 7/2024 (final provision 17) asks the government to push for an EU change so platforms charge and pay the VAT on short-term rentals. It is a mandate, not a rule in force.

Quick checklist

Keep every commission invoice and check who issues it.
If it has no VAT and mentions the reverse charge, ask your adviser about the 303 and modelo 349 (key I).
Check that you are registered in the ROI (modelo 036).
If you rent an exempt holiday let, ask specifically about the commission.
This is not tax advice: check with your adviser.

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Frequently asked questions

Why does the Booking.com invoice come without VAT?

If a company from another EU country issues it and you are a business in Spain, you normally declare the VAT yourself (reverse charge, art. 84.Uno.2.º a) of the VAT Act). There are exceptions, such as intermediation in property rentals.

Do I have to file modelo 349?

The Tax Agency says intra-EU acquisitions of services are reported in modelo 349, with key I. Confirm it with your adviser for your case.

I am a private owner with a holiday let. Does this affect me?

The VAT Act treats lessors of property as businesses. But since 1 January 2023 a non-established platform's intermediation in property rentals is not reverse-charged: the platform charges you Spanish VAT (ruling V3292-23 of the Directorate General for Taxes, 21 %). If your rental is exempt, you cannot deduct it. Confirm it with your adviser.

Sources

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