Are you a Dutch e-commerce entrepreneur selling in Spain via Amazon FBA, Bol or your own webshop? Sooner or later you will have to deal with Spanish VAT. As soon as you store inventory in Spain, for example in an Amazon warehouse, you need a Spanish VAT number and must file a local VAT return with the Agencia Tributaria (AEAT). Do you only sell remotely from the Netherlands to Spanish consumers? Then the EU threshold of 10,000 euros applies and you arrange that through the One Stop Shop (OSS) in the Netherlands. In this blog we explain when you need to file in Spain, which forms are involved, which deadlines apply in 2026 and how to submit your return step by step.
When do you need to file a VAT return in Spain?
The trigger for a local Spanish VAT return is: you store inventory in Spain. This can happen because you store products yourself in your own fulfilment location or an Amazon warehouse, but also because you use Amazon FBA, where Amazon can store your products in Spanish warehouses and ship from there.
As soon as you have a Spanish VAT number, you must periodically submit a VAT return to the Agencia Tributaria (AEAT), the Spanish tax portal. This applies even if you had no turnover in Spain during a certain period: a so-called nil return is then mandatory.
Do you sell remotely from the Netherlands to Spanish consumers? Then the EU threshold of 10,000 euros applies. If you exceed that threshold, you charge the Spanish VAT rate. You can declare those sales through the One Stop Shop (OSS) in the Netherlands, but you may also choose to register locally in Spain and file there. However, as soon as you have inventory in Spain, a local Spanish registration and return is always mandatory, regardless of whether you also use the OSS.
What returns exist in Spain?
In Spain you deal with several different forms. The most important ones:
- Modelo 303 – the periodic VAT return. This is the core of your VAT obligation. You report your VAT due and your deductible input tax. Depending on your situation, you submit this quarterly or monthly.
- Modelo 390 – the annual VAT summary. This is a summarising annual overview of all your VAT transactions for the past year. You submit this in January for the previous year. Note: entrepreneurs covered by the SII are exempt from the Modelo 390.
- Modelo 349 – the intra-community transactions return (ICP). Similar to the Dutch ICP return. You report your intra-community supplies and acquisitions to other VAT-registered businesses within the EU.
- SII (Suministro Inmediato de Información). This is not a separate form, but a system of near real-time submission of your invoicing data. Monthly filers and large businesses are required to submit their VAT records digitally to the AEAT within a few days.
Overview: which return, how often and which form?
| Return | How often? | Deadline | Form |
|---|---|---|---|
| Periodic VAT return | Quarterly (or monthly) | Quarterly: day 20 of April, July, October and January. Monthly: day 30 of the following month | Modelo 303 |
| ICP return (intra-community transactions) | Monthly or quarterly | First 20 days of the following month/quarter | Modelo 349 |
| Annual VAT summary | Annually | 1 to 30 January (for the previous year) | Modelo 390 |
| Real-time VAT records submission | Ongoing (mandatory for monthly filers/large businesses) | Within 4 working days after issuing the invoice | SII |
How often do you need to file?
Most Dutch e-commerce entrepreneurs with a Spanish VAT number submit their Modelo 303 quarterly. That is the standard regime.
You must file monthly in several situations. The most well-known is registration in REDEME (Registro de Devolución Mensual), the register for monthly VAT refunds. Many e-commerce entrepreneurs register for this because they are often in a refund position due to imports and purchases, and do not want to wait a whole year for their money. Once you are in REDEME, you are required to file monthly and automatically fall under the SII.
In addition, large businesses must file monthly: companies with turnover above 6,010,121.04 euros in the previous year (the “grandes empresas”), and VAT fiscal units. These also fall under the SII.
In short:
- Quarterly return: the standard regime for most sellers.
- Monthly return: mandatory for REDEME registrations, for turnover above 6,010,121.04 euros and for VAT groups. This group also falls under the SII.
The 2026 deadlines at a glance
For quarterly filers, you submit the Modelo 303 in the first 20 days of the month after the quarter. For the fourth quarter you have a little more time: until 30 January.
- Q4 2025: no later than 30 January 2026
- Q1 2026: no later than 20 April 2026
- Q2 2026: no later than 20 July 2026
- Q3 2026: no later than 20 October 2026
- Q4 2026: no later than 30 January 2027
For monthly filers, you submit the Modelo 303 in the first 30 days of the following month. The return for January may be submitted no later than the last day of February.
The Modelo 390 (annual summary for 2025) is submitted between 1 and 30 January 2026. The Modelo 349 follows essentially the same rhythm as your Modelo 303: monthly or quarterly, in the first 20 days after the period. You may submit the Modelo 349 quarterly as long as your intra-community supplies do not exceed 50,000 euros; above that you become a monthly filer.
Note: if a deadline falls on a Saturday, Sunday or public holiday, it shifts to the next working day. Also plan ahead, as payments via direct debit (domiciliación) usually need to be submitted a few days before the deadline.
What happens if you are late?
If you are late filing or paying, the Agencia Tributaria charges a surcharge (recargo). If you file late voluntarily — before the tax authority contacts you — the following applies:
- 1% base surcharge, plus 1% extra for each full month of delay, up to a maximum of 12 months.
- If you are more than 12 months late, the surcharge is 15%, plus interest (interés de demora) from the thirteenth month.
If you pay the surcharge and the tax debt on time after the reminder, you often receive a 25% discount on the recargo. If you wait until the tax authority contacts you, costs rise significantly and real penalties (sanciones) may also follow. In short: late is always more expensive, so keep a close eye on your deadlines.
Step-by-step guide: how to file your Spanish VAT return
- Register for Spanish VAT. As soon as you have inventory in Spain, apply for a Spanish VAT number (NIF-IVA) with the Agencia Tributaria. You need a digital certificate to be able to log in and file online.
- Determine your filing frequency. Will you file quarterly, or register for REDEME to file monthly and receive your refund sooner? With monthly filing you also fall under the SII.
- Keep your administration in order. Make sure your sales and purchase invoices, import documents and Amazon/Bol transactions are complete and correct. Apply the correct VAT rates: 21% (standard), 10% (reduced) and 4% (super-reduced) for certain products.
- Submit your data via SII (if applicable). If you fall under the SII, send your VAT records digitally to the AEAT within 4 working days of issuing an invoice.
- Submit the Modelo 303. Log in to the Agencia Tributaria portal, fill in your VAT due and deductible input tax, and submit before the deadline.
- Don’t forget the additional returns. Submit the Modelo 349 (ICP) where required and, at the start of the year, the Modelo 390 (annual summary) — unless you fall under the SII and are exempt from it.
- Pay on time. If you owe a balance, pay before the deadline, preferably via direct debit so you don’t forget anything.
Point of attention for 2026: Veri*factu and e-invoicing. Spain is introducing a new system of certified invoicing software, where invoices are linked to the AEAT in real time or in a verifiable way. The obligation for businesses is being phased in: expected from 1 January 2027 for companies and from 1 July 2027 for sole traders. Keep an eye on these developments, especially if you use your own invoicing software.
OSS or local return in Spain?
The big question for many entrepreneurs: do I handle everything through the OSS in the Netherlands, or do I need to register locally in Spain? The answer depends on your inventory.
- No inventory in Spain, only remote sales? Then you settle the Spanish VAT on your B2C sales via the OSS return in the Netherlands, once you exceed the EU threshold of 10,000 euros. You do not need to register in Spain.
- Do you have inventory in Spain (for example Amazon FBA)? Then a local Spanish VAT number and a local Modelo 303 return are mandatory. The OSS does not cover local stock movements and domestic supplies in Spain.
In practice, many e-commerce entrepreneurs have a combination of both: OSS for their cross-border sales and local returns in the countries where their inventory is held. That quickly becomes complex. Not sure which regime applies to you, or getting stuck in the Spanish portal? Our VAT specialist Joke is happy to help you get your registration and returns in Spain fully in order, so you can keep selling with peace of mind.
