Hotel gift vouchers and gift cards: expiry, refunds, what to include and VAT (2026)

Updated: 10 November 2026

Selling a night or a short break as a gift brings cash in advance and new guests. But questions follow: can it expire? Must you refund? When is VAT due? We read EU Directive 2016/1065, the Andalusian consumer authority's notes and official tax documents from Spain, Portugal, Italy and Greece (links at the end). Where we could not confirm something we say so. This is not legal advice: check with your adviser.

Two kinds of voucher

Voucher for a specific service: "one night for two at our hotel, breakfast included".
Gift card with an amount: "EUR 150 to spend at the hotel".
For VAT the key point is not the format but whether, when you sell it, you already know where and at what VAT rate the service will be supplied.

Expiry: what Andalusia's consumer authority says

Official Consumo Responde notes (Regional Directorate-General for Consumer Affairs):

January 2025: issued vouchers, including gift cards, cannot have an expiry date; setting one is an illegal practice.
January 2026: gift vouchers and gift receipts cannot expire; gift cards with a monetary value may have a validity period, usually at least three years from issue.
Neither note cites the specific legal article it relies on.
In practice: do not set a short expiry. If you set a period, make it long, clear and visible before purchase, and check with your adviser.

A specific Andalusian rule: not found

We found no Andalusian act or decree that specifically regulates gift card expiry. What exists are the consumer authority's notes cited above. We did not review other Spanish regions.

Refunds and unfair terms

Consumo Responde note on an inspection campaign:

The regional government fined a chain for selling gift cards with an expiry date.
Inspectors held that keeping the unused balance of an expired card was unfair: the business is paid and gives nothing in return.
Wording such as "not refundable or exchangeable for cash" on a card that expires is what was challenged.
If the guest cannot use the voucher, offer another date or a refund of the unused amount, and keep it in writing.

VAT: the EU rule since 2019

Directive (EU) 2016/1065 (OJ L 177, 1-7-2016), for vouchers issued after 31-12-2018:

Single-purpose voucher: the place of supply and the VAT due are known at issue. Each sale of the voucher is treated as the service itself: VAT is due on sale, not on redemption.
Multi-purpose voucher: any other (for example, valid at hotels in several countries). Not taxed on sale; the service is taxed when supplied.
Taxable amount of a multi-purpose voucher: what was paid for it or, if unknown, its monetary value, less VAT.
A voucher for a night at your hotel in Spain, with a known VAT rate, fits the single-purpose definition. Confirm with your adviser.

VAT in Spain

The Directorate-General for Taxation issued a resolution on vouchers in VAT (28-12-2018, Official Gazette of 31-12-2018, BOE-A-2018-18094). According to the Tax Agency, a voucher is single-purpose when, at issue, it is known with certainty where the supply is taxed and at what rate (or that it is exempt); otherwise it is multi-purpose.

Portugal

Portuguese VAT Code, rules introduced by Law 71/2018 for vouchers issued from 1-1-2019 (binding ruling of the Tax Authority):

Single-purpose voucher (vale de finalidade única): VAT on each transfer (art. 7, no. 13).
Multi-purpose voucher (vale de finalidade múltipla): VAT when the service is supplied (art. 7, no. 14); taxable amount under art. 16, nos. 13 to 15.
Minimum validity of vouchers for consumers: no rule found in an official source.

Italy and Greece

Italy: buoni-corrispettivo, arts. 6-bis, 6-ter and 6-quater of DPR 633/1972 (Legislative Decree 141/2018). Single-purpose (monouso): VAT on issue; multi-purpose (multiuso): when the service is supplied.
Greece: Law 4607/2019, art. 12a of the VAT Code, explained in AADE circular E.2111/2019: same scheme since 1-1-2019.
In both countries we have not confirmed a consumer rule on minimum validity of gift vouchers.

What to put on the voucher and how to book

Good practice (not a legal list):

What is included: room type, nights, guests, board (breakfast etc.) or the amount.
When it can be used: excluded seasons, if any, and any validity period; all visible before purchase.
How to book: which channel, how far ahead and what happens if there is no availability.
Whether it can be transferred or refunded, and how.
A unique code, the issue date and your business details.
When the guest books with the voucher, honour the terms published when it was sold: do not change the rules afterwards.

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Frequently asked questions

Can a gift voucher for my hotel expire?

Andalusia's consumer authority says gift vouchers cannot expire, and that cards with an amount may have a validity period, usually at least three years. It does not cite the specific article: check with your adviser.

When do I pay VAT on a one-night voucher?

If it is single-purpose (you know where and at what VAT rate the service is supplied), on sale. If it is multi-purpose, when the guest uses it. This is the Directive 2016/1065 rule, applied in Spain, Portugal, Italy and Greece.

What if the guest never uses it?

We have not confirmed in an official source how to treat an unredeemed voucher for VAT. On the consumer side, the Andalusian authority held that keeping the unused balance of an expired card was unfair.

Sources

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