Amazon FBA and VAT in Spain
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But alongside this opportunity comes something many new sellers don’t expect — Spanish VAT for Amazon FBA.
Understanding the Spanish VAT System (IVA)
The Spanish value-added tax, known locally as Impuesto sobre el Valor Añadido (IVA), is more than just a formality. It’s a legal obligation, and ignoring it can lead to serious trouble — from heavy fines to account suspension on Amazon. Spain’s tax authorities are known for being particularly strict when it comes to e-commerce compliance.
If you sell products using Amazon FBA, you should know that the Spanish system is designed to track every movement of goods, every sale, and every report. Nothing slips through the cracks.
When VAT Obligations Begin — Often Sooner Than You Think
For many sellers, the issue begins innocently enough. You enable Pan-European FBA, and Amazon automatically moves part of your stock to a warehouse in Barcelona or Madrid. A few weeks later, you receive a notification that you must register for Spanish VAT.
In theory, this sounds like a minor administrative step. In practice, it’s a full legal obligation towards the Spanish tax authorities. Many first-time sellers underestimate this, not realizing that simply storing goods in an Amazon FBA warehouse in Spain already triggers the requirement to register for VAT — even if you haven’t made a single sale there yet.
Why VAT Matters So Much
VAT determines whether your business is operating legally or not. In the world of Amazon FBA, borders between countries fade fast — but tax borders remain, and they are strictly enforced.
In Spain, the tax office not only expects you to charge and pay VAT according to local rules but also to report every transaction in a specific format. If you store and sell from multiple countries, you must understand which sales are considered local and which are intra-EU. This distinction affects how you report your VAT and whether you need to register in multiple countries.
What You’ll Learn in This Guide
In this article, we’ll walk you through everything you need to know about Amazon FBA VAT in Spain — from registration requirements and VAT rates to obtaining a Spanish NIF-IVA number. We’ll explain how the rules differ for EU and non-EU businesses, and what the VAT reporting process looks like in practice.
We’ll also cover how Amazon handles VAT within its Pan-European FBA program, what the One Stop Shop (OSS) system is, and — importantly — why it doesn’t automatically exempt you from registering in Spain.
You’ll also find practical details: filing deadlines, form templates, an explanation of the Modelo 303 quarterly VAT return, the annual Modelo 390, and the SII (Immediate Information Supply) system — Spain’s real-time invoice reporting framework.
And because prevention is better than cure, we’ll show you the most common mistakes sellers make and how to avoid them.
By the end of this guide, you’ll know when and how to register for VAT, how to handle your returns, when OSS applies, and what your obligations are when storing goods in Spain. Most importantly, you’ll understand how to stay fully compliant with Spanish tax law — and keep your Amazon account safe from VAT-related issues.
So, let’s start from the beginning — what exactly is Spanish VAT, how does it work, and why does it matter so much for Amazon FBA sellers?
What Is VAT in Spain (IVA)?
How the Spanish VAT System Works and What the Rates Are
The Spanish value-added tax, known as Impuesto sobre el Valor Añadido (IVA), is the cornerstone of the country’s tax system for every business operating in e-commerce. It works much like VAT in other EU countries — a consumption tax applied at every stage of production, distribution, and sale. While the end customer ultimately pays it, the seller (for example, an Amazon FBA merchant) acts as a tax collector, charging VAT on sales and forwarding it to the Spanish tax authorities.
The institution responsible for overseeing VAT registration, collection, and reporting in Spain is the Agencia Estatal de Administración Tributaria (AEAT) — Spain’s National Tax Agency. AEAT manages not only VAT registrations and the issuing of NIF-IVA numbers but also the verification of VAT reports submitted by businesses. It also operates the country’s digital reporting system known as SII (Suministro Inmediato de Información), a near real-time invoice reporting mechanism.
The SII System – Real-Time VAT Monitoring
The SII system is mandatory for large taxpayers (those with annual turnover exceeding €6 million), companies that apply for monthly VAT refunds (REDEME), and VAT groups. Smaller businesses can opt in voluntarily.
Under SII, invoice data — both sales and purchase invoices — must be submitted within four working days of being issued or received. This allows AEAT to cross-check data between taxpayers almost instantly, significantly tightening control over VAT compliance in the e-commerce sector.
VAT Rates in Spain
Spain applies three main VAT rates, which are uniform across the entire country:
- 21% – the standard rate, applied to most goods and services such as electronics, clothing, cosmetics, home appliances, furniture, and sports accessories.
- 10% – the reduced rate, which covers restaurant and hospitality services, passenger transport, and some food products. The exact rate depends on product classification under the CN (Combined Nomenclature) code.
- 4% – the super-reduced rate, applied to essential goods such as bread, milk, fruit, vegetables, books (including e-books since 2020), newspapers, and certain medicines.
Exports (sales outside the EU) and intra-EU B2B supplies are VAT-exempt with the right to deduct (exento con derecho a deducción). This isn’t a formal “0% rate” but a special exemption that still allows sellers to deduct VAT on related purchases.
Cross-Border B2C Sales and OSS
For B2C sales to other EU countries, such as when a seller in Spain ships products to customers in Germany, the principle of taxation in the country of consumption applies. In practice, such transactions are reported through the OSS (One Stop Shop) system, using the VAT rates applicable in the buyer’s country.
Recent VAT Rate Updates in Spain
As of January 1, 2025, Spain introduced adjustments to VAT rates for certain food products. These changes stem from Royal Decree RDL 4/2024, which ended temporary rate reductions that had been in place during periods of high inflation.
Under the new rules, olive oil is now permanently classified as a basic product and taxed at 4%, while seed oils and pasta have returned to the 10% rate. These updates apply only to the Spanish domestic market and are not part of the EU-wide VAT reform.
What This Means for Amazon FBA Sellers
For FBA sellers, these rate changes mean one thing: stay alert. You need to regularly monitor product classifications and update VAT rates in Amazon Seller Central.
For example, if you sell books — whether printed or digital — you’ll apply 4%. Ready-to-eat meals, coffee, or processed foods usually fall under 10%, while dietary supplements, cosmetics, and electronics typically remain at 21%.
Always double-check your product’s classification in AEAT’s official catalog, since misclassifying a VAT rate is one of the most common reasons for tax corrections.
Data Transparency and Reporting
While AEAT doesn’t literally “see every invoice” in real time, it does analyze data submitted by businesses covered under SII and by marketplaces like Amazon. This enables it to detect inconsistencies and reporting errors efficiently.
In short, Spain’s VAT system is transparent but unforgiving. Accuracy matters. For any seller using Amazon FBA, this means not only registering for VAT but also understanding how product classifications and VAT rates directly affect your tax filings.
In the next section, we’ll look at when exactly the obligation to register for VAT in Spain arises — and how the registration process works step by step.
When Do You Need to Register for VAT in Spain?
For many Amazon FBA sellers, the moment when VAT registration in Spain becomes mandatory often comes as a surprise. But in reality, the rules are quite straightforward: if you exceed the EU-wide B2C sales threshold or store goods within Spain, you must register for a local VAT number (NIF-IVA) and file VAT returns with the Spanish tax authorities.
EU-Based Sellers
If your business is registered in an EU country — for example, in Germany, France, or Italy — the obligation to register for Spanish VAT can arise in two main situations.
The first concerns distance sales, meaning intra-EU sales of goods to consumers (WSTO). Since 1 July 2021, the EU has applied a single €10,000 annual threshold for all cross-border B2C sales combined across the EU. Once you exceed that amount, you must apply VAT based on the country of your customer — the so-called country of consumption.
At that point, you can either:
- register for VAT in each country where you sell, or
- use the One Stop Shop (OSS) system, which allows you to report all your cross-border B2C sales in one single quarterly return submitted in your home country.
Keep in mind that the €10,000 threshold only applies to intra-EU B2C sales of goods and certain digital services (telecom, broadcasting, and electronic services). It does not apply to imports from outside the EU. For imported goods, you must use the Import One Stop Shop (IOSS) for shipments worth up to €150, or declare VAT upon import for higher values.
The second situation where Spanish VAT registration becomes mandatory is when you store goods in Spain, such as through Amazon’s Pan-European FBA program. If Amazon stores any of your inventory in a fulfillment center in Spain, you must register for Spanish VAT — even if you haven’t sold a single item there yet.
Simply moving goods into Spain is treated as an intra-EU supply from the country of origin and an intra-EU acquisition in Spain.
In practice, this means you must not only register with AEAT (the Spanish tax authority) but also include these movements in your Modelo 303 VAT return (under the intra-EU acquisition section) and in the Modelo 349 summary report. Since your stock is physically located in Spain, AEAT considers that you are conducting taxable business activity there — and expects you to report and pay local VAT accordingly.
Marketplace Data Reporting and DAC7
Since 2023, marketplaces like Amazon are legally required to share detailed information about their sellers with EU tax authorities under the DAC7 Directive. In Spain, this reporting is done through Form 238, which allows AEAT to cross-check data about your sales and inventory movements.
In short: if your products are stored in Spain but you haven’t registered for VAT, it’s only a matter of time before AEAT finds out.
VAT Returns and Filing Deadlines
Once registered, EU-based businesses must file Modelo 303 VAT returns quarterly, between the 1st and 20th day following the end of each quarter (for Q4, until January 30).
Additionally, an annual summary return — Modelo 390 — must be filed by January 30 of the following year. However, taxpayers using the SII real-time reporting system are generally exempt from filing Modelo 390, since their data is already submitted continuously.
Non-EU Sellers
For businesses based outside the EU — such as from the UK, the US, or Asia — the rules are slightly different. The obligation to register for VAT in Spain arises as soon as you make your first domestic sale within Spain or store inventory in an Amazon fulfillment center there.
If you import goods from outside the EU and the value of a single shipment is below €150, you can handle VAT through the IOSS system, which removes the need for Spanish VAT registration. For shipments above that value, VAT is due at import.
However, in most cases where a non-EU seller uses Amazon FBA or sells directly within Spain, they must appoint a fiscal representative (representante fiscal). This is a locally registered tax agent who acts on behalf of your company before AEAT and shares joint responsibility for your VAT obligations.
This requirement applies to all non-EU countries except those with formal cooperation agreements on tax matters with the EU — currently, this includes Norway.
Registration Deadlines and Late Penalties
You must register for VAT before you begin selling or storing goods in Spain. The registration is done using Form Modelo 036. If your company details change (for example, address or representative), you must update the registration within 30 days of the change.
If you file your registration or VAT return late, AEAT doesn’t impose a flat fine but instead applies a recargo por declaración extemporánea — a surcharge for late submission.
This surcharge is 1% per full month of delay, increasing up to 15% plus interest after 12 months. These rates apply if you voluntarily file your late return before AEAT sends you a reminder.
If AEAT detects the delay and issues a formal notice, penalties can range from 50% to 150% of the unpaid VAT, depending on the seriousness of the violation and whether it’s deemed intentional.
For zero or negative VAT returns, AEAT often applies fixed fines — typically around €200. Submitting a late registration form (Modelo 036 or 037) usually results in a penalty of about €400.
In extreme cases — such as repeated failure to file returns — AEAT can revoke your NIF-IVA and remove your business from the ROI (Registro de Operadores Intracomunitarios) and the VIES database. This effectively blocks you from conducting intra-EU B2B transactions and can cause major disruptions to your Amazon account.
Final Word of Advice
If you sell through Amazon FBA, always keep track of where your stock is stored. If Amazon moves your goods to Spain, act immediately and register for VAT before issues arise. It’s far better to be registered and compliant from the start than to face fines — or worse, an account suspension.
Amazon FBA and VAT Obligations — The Most Common Scenarios
Amazon FBA is an incredible tool that allows online sellers to reach international markets without setting up physical offices or warehouses abroad. For many European e-commerce entrepreneurs, it’s one of the easiest paths to expansion — but it’s also one of the main sources of tax misunderstandings.
In Spain, one of Amazon’s largest European markets, the rule is simple: if your goods are physically stored in Spain, you must register for and report Spanish VAT.
Storing Goods = Automatic VAT Obligation
Under Spanish tax law, simply storing goods in Spain is considered conducting business activity on Spanish territory. This stems directly from Articles 5 and 84 of the Spanish VAT Act (Ley 37/1992 del IVA).
In practice, this means that if Amazon moves your products from a warehouse in one EU country — say Germany or Poland — to a warehouse in Spain, this is treated as an intra-EU transfer of goods. For tax purposes, that movement counts as both an intra-EU supply in the sending country and an intra-EU acquisition in Spain.
From the perspective of the Spanish Tax Agency (AEAT), it doesn’t matter how much you sell, or whether any of those products have been purchased yet — the mere presence of your stock in Spain triggers a VAT registration requirement and the obligation to include those transactions in your VAT returns.
Once registered, sellers must submit Modelo 303 VAT returns and Modelo 349 summary statements. In most cases, these are filed quarterly, but sellers in the REDEME scheme (monthly VAT refunds) or those using the SII real-time reporting system report monthly instead. AEAT requires that all intra-EU acquisitions and supplies are correctly declared, and inconsistencies may lead to automatic correction requests.
Since 2024, things have become even more transparent. Amazon, like all major marketplaces, is required to share detailed seller data with AEAT under the DAC7 Directive, implemented in Spain via Form 238. This means AEAT receives information on warehouse locations, sales values, transaction volumes, and who is actually trading on the Spanish market. Any discrepancies between Amazon’s reports and AEAT’s records can result in an audit or a request for registration.
Pan-European FBA
The Pan-European FBA program allows Amazon to freely distribute your products across fulfillment centers throughout the EU — including Spain, Germany, France, Italy, Poland, the Czech Republic, and the Netherlands, with more countries being added regularly.
This means your inventory can be moved between countries without your direct involvement, but each such transfer creates a local VAT obligation.
For tax purposes, Amazon’s movements of goods between EU warehouses are treated as intra-EU supplies and acquisitions. Therefore, sellers must register for VAT in every country where their stock is stored.
It’s important to note that you cannot use the OSS (One Stop Shop) system to avoid local VAT registrations in storage countries. OSS only covers distance sales to consumers (B2C), not physical storage of goods.
In practice, local VAT registration and OSS complement each other. OSS is used for cross-border B2C sales, while local VAT numbers cover domestic sales and stock movements.
So if you participate in Pan-European FBA, you must have VAT numbers in each country where Amazon keeps your goods. Failure to register in one of those countries can lead to serious consequences — AEAT can revoke your NIF number, remove you from the ROI (Registro de Operadores Intracomunitarios), and request your removal from VIES, effectively cutting you off from intra-EU trading. For Amazon sellers, that means the end of cross-border operations within the EU.
Local vs. Cross-Border Sales
From a VAT standpoint, understanding the difference between local and cross-border sales is crucial.
Local sales occur when goods are shipped and delivered within the same country — for instance, from an Amazon warehouse in Spain to a customer in Spain. These transactions are subject to Spanish VAT and must be reported in the Modelo 303 return. Invoices should include your Spanish VAT number and the correct VAT rate — typically 21%, unless the product qualifies for a reduced or super-reduced rate.
Cross-border sales, on the other hand, involve shipments from Spain to customers in other EU countries.
For B2C transactions, these are treated as intra-EU distance sales (WSTO). VAT is applied in the buyer’s country, and sales are reported via the OSS system — registered in your country of establishment (for example, in France or Germany).
However, B2B transactions — sales to VAT-registered businesses in other EU countries — cannot be reported through OSS. They must be declared separately and included in the Modelo 349 report.
In short, FBA sellers need to clearly distinguish which transactions are domestic and which are cross-border. Misclassifying them can lead to incorrect VAT rates or misreporting in the wrong country. AEAT pays close attention to this, so it’s essential to use Amazon’s transaction reports to verify the warehouse of origin and the destination country for every sale.
For many EU sellers, the key takeaway is simple: OSS does not replace local VAT registration in storage countries. You can report your cross-border sales via OSS in your home country, but if your goods are stored in Spain, you must also have a Spanish VAT number and file local returns. These are two parallel systems that together form the full VAT framework under Pan-European FBA.
Proper understanding of these rules not only helps avoid fines and audits but also prevents potential issues with Amazon, which can suspend your account if tax inconsistencies are detected. The Spanish tax authorities are known for strict enforcement, so it’s always better to register early and stay compliant. That way, your Amazon FBA operations in Spain remain smooth, legal, and profitable.
VAT Registration in Spain for EU-Based Sellers
For businesses based in the EU, registering for VAT in Spain is a mandatory step if you sell goods through Amazon FBA or store inventory in Spanish warehouses. The process is handled by the Agencia Estatal de Administración Tributaria (AEAT) — Spain’s national tax authority responsible for all VAT matters.
The core of the registration process is Form Modelo 036, used to obtain your tax identification number (NIF) and formally declare your taxable activities in Spain.
You can file the form at a local AEAT office or online, but most foreign businesses use a local tax representative with a Spanish digital certificate (FNMT). AEAT’s online system accepts only recognized Spanish digital signatures or certificates listed in the EU Trusted List, which is why many EU companies delegate this step to local agents.
To obtain a NIF, you’ll need to submit documents confirming your company’s legal existence and structure. AEAT typically requires:
- an extract from your business registry (e.g., commercial register or national business database),
- details of the business owner and legal representatives,
- a copy of a passport or ID, and
- a power of attorney if a tax agent files on your behalf.
In some cases, AEAT may request certified Spanish translations of your documents, depending on the local office’s requirements.
Once your documents are verified, AEAT issues a temporary NIF so you can begin operations. After full validation and registration in the Registro de Operadores Intracomunitarios (ROI), it becomes an active NIF-IVA — your official EU VAT number visible in the VIES database.
This number allows you to make intra-EU transactions and issue invoices with Spanish VAT.
The entire process typically takes 7–10 business days, although it can vary depending on the region and administrative workload. The Spanish VAT number format is ES + 9 characters, for example, ESX1234567X, and this prefix must appear on all invoices issued in Spain or within the EU.
After registration, you’re required to file regular VAT returns. The standard schedule in Spain is quarterly, meaning you’ll file Modelo 303 four times a year. However, high-turnover businesses or those in the REDEME monthly refund scheme may need to report monthly instead.
Most taxpayers must also submit an annual summary return (Modelo 390), which covers all VAT activity for the year. Sellers using the SII system are exempt from this, as their transactions are reported in real time.
All returns are filed electronically through the AEAT online portal — Spain no longer accepts paper submissions from foreign businesses. You’ll need to log in using a digital certificate or the Cl@ve identification system, AEAT’s official online authentication method.
Registering for VAT in Spain as an EU-based business is a straightforward but detail-oriented process. The most important thing is to prepare accurate documentation and submit Form 036 before you begin selling or storing goods in Spain. Only after your VAT number is activated in the VIES system can you legally issue invoices with Spanish VAT and remain compliant with AEAT regulations.
How to Report and Pay VAT in Spain
Spain is known for its precision in VAT reporting. The Spanish Tax Agency (AEAT) operates a system that requires regular, electronic VAT declarations and consistent data across quarterly and annual reports.
For Amazon FBA sellers, this means one thing: you must maintain detailed, accurate transaction records. The key forms are Modelo 303, used for ongoing VAT filings, and Modelo 390, which serves as the annual summary. Depending on your business activity, you may also need to file Modelo 349 for intra-EU transactions and Modelo 347 for reporting Spanish business partners when annual transactions with a single entity exceed €3,000.
Modelo 303 — Quarterly VAT Returns
Modelo 303 is the core VAT return required from all VAT-registered businesses in Spain. AEAT only accepts electronic submissions through its online portal.
Most Amazon FBA sellers file quarterly, but some — particularly those with high turnover, those enrolled in REDEME (monthly VAT refund system), or those using SII (Suministro Inmediato de Información) real-time reporting — must file monthly instead.
The quarterly deadlines are fixed and haven’t changed for years:
April 20, July 20, October 20, and January 30 (for Q4).
VAT payments must be made by the same date the declaration is filed. However, if you opt for direct debit (domiciliación bancaria), the declaration must be submitted by the 15th of that month — AEAT will then automatically withdraw the amount due from your Spanish bank account.
Keep in mind: AEAT does not accept payments from non-SEPA accounts. If you don’t have a Spanish bank account, you can still pay using an NRC (Número de Referencia Completo) — a reference code generated by banks authorized to operate with AEAT.
How VAT Calculation Works in Modelo 303
The math itself is simple, but accuracy is key. You report:
- IVA repercutido — VAT charged on your sales
- IVA soportado — VAT paid on your purchases and business expenses
The difference between them determines what you owe or what you can reclaim:
VAT payable = VAT collected – VAT incurred
If the result is positive, you must pay that amount to AEAT.
If it’s negative, you can carry the balance forward to the next period or request a refund (devolución). Refunds are normally available once a year, in the fourth-quarter declaration, unless you’re part of the REDEME scheme, which allows monthly refunds.
Example:
Let’s say your Amazon FBA sales in Spain for the quarter total €10,000 (net). You charged €2,100 in VAT, and paid €600 in VAT on logistics and Amazon fees.
Your VAT liability = €2,100 – €600 = €1,500.
This amount must be paid by the 20th of the month following the quarter’s end.
Correcting VAT Returns
If you make a mistake, you can fix it using a declaración complementaria (to add missing data) or a rectificación de autoliquidación (when the correction changes the VAT amount).
If the error caused you to underpay VAT, you must file a declaración sustitutiva, which replaces the previous one entirely.
For late voluntary corrections, AEAT applies the recargo por declaración extemporánea — a 1% surcharge per month of delay (up to 12 months), and after one year, 15% plus interest.
Modelo 390 — Annual VAT Summary
Modelo 390 is an informational summary, not a payment form. It consolidates all VAT data for the entire calendar year and must exactly match the quarterly Modelo 303 submissions.
In practice, Modelo 390 includes totals for sales and purchases by VAT rate (21%, 10%, 4%), as well as data on corrections, imports, intra-EU acquisitions and supplies, and any carry-forward balances. AEAT uses this form to cross-check data — even small inconsistencies can trigger a correction request.
The submission deadline is January 30 of the year following the tax year. Modelo 390 must be filed electronically using a digital certificate or the Cl@ve system.
Some taxpayers are exempt from filing Modelo 390, including:
- businesses using SII (real-time VAT reporting),
- participants in the REDEME monthly refund system, and
- sellers who report all B2C sales exclusively via OSS.
In these cases, AEAT already holds the necessary data in its systems and doesn’t require a separate annual summary.
If you later discover errors in Modelo 390, you can submit a declaración sustitutiva (replacement return), indicating that it replaces the previous version. AEAT typically does not impose penalties for voluntary corrections made within a reasonable time.
Why the Annual Summary Matters
Beyond being a formal requirement, the annual VAT summary is a valuable internal control tool. It allows you to verify whether data reported to AEAT, Amazon, and via OSS are all consistent.
Spain’s tax authority places heavy emphasis on data coherence between systems, so keeping your transaction reports organized and archived isn’t just compliance — it’s your best safeguard against potential disputes.
For Amazon FBA sellers in Spain, submitting Modelo 303 and 390 accurately and on time is absolutely essential to maintaining an active VAT number and avoiding sanctions.
Missing even a single declaration — even one with a zero balance — is treated as a reporting violation and may lead to fines or administrative proceedings.
In practice, just one missed return can result in AEAT suspending your NIF number or removing you from the ROI, which automatically blocks your ability to continue selling across the EU.
The SII System — Real-Time VAT Reporting in Spain
Spain ranks among Europe’s leaders in digital tax control, and one of the key innovations behind this reputation is the SII system — Suministro Inmediato de Información, which literally means “Immediate Supply of Information.” Introduced on 1 July 2017 under Royal Decree 596/2016, the system was designed to modernize VAT reporting and drastically shorten the gap between issuing an invoice and reporting it to the tax authority.
How the SII System Works
In essence, SII changes how businesses communicate their VAT data to AEAT, the Spanish tax agency. Instead of sending copies of invoices, taxpayers transmit structured invoice data — information such as invoice numbers, dates, customer details, amounts, VAT rates, and the nature of each transaction. These details are sent electronically in XML format, following AEAT’s strict technical standards. Once submitted, the system immediately validates the data, confirming or rejecting it if it detects errors.
SII completely replaced the old paper-based VAT books known as libros registro del IVA. Companies using the system no longer maintain separate ledgers, because AEAT already holds all their data in real time. As a result, businesses registered under SII no longer need to file the annual summary known as Modelo 390, since the tax office already has a complete picture of their VAT activity. They still, however, file Modelo 303, but on a monthly basis rather than quarterly, which allows for faster settlements and refunds.
Who Needs to Use SII
The SII system is compulsory for large businesses whose annual turnover exceeds €6 million, for companies that participate in the monthly VAT refund scheme known as REDEME, and for members of VAT groups. Smaller businesses can also opt in voluntarily if they wish to automate reporting and gain full visibility of their VAT data within the AEAT system.
To join voluntarily, you must submit Modelo 036, selecting the option Alta en el SII. Once approved, participation begins on the first day of the next reporting period, usually the start of the following month. It’s worth noting that opting in to SII automatically means switching to a monthly VAT reporting cycle.
For most Amazon FBA sellers, joining SII is only mandatory if their annual sales exceed the legal threshold or if they are enrolled in REDEME. Other sellers can participate voluntarily, but this is relatively rare, as it requires integrating your accounting software with AEAT’s API and maintaining continuous invoice reporting — a process that demands both time and technical setup.
Deadlines and Data Format
Spain’s SII system runs on tight deadlines. Businesses must transmit invoice data within four working days from the date the invoice is issued or recorded. Weekends and public holidays are not counted. When SII was first introduced, the timeframe was eight days, but this was later reduced to ensure faster reporting.
All information is sent electronically through AEAT’s secure API in four separate registers: one for sales invoices, another for purchase invoices, a third for intra-EU operations, and one more for fixed-asset investments. Each submission is checked immediately, and if an entry is rejected, the business has ten working days to correct and resend it. AEAT stores all submitted files permanently, so both the taxpayer and the tax authority have identical, synchronized records.
For Amazon sellers, this means that data from invoices issued in Spain must reach AEAT automatically. Amazon itself does not handle this process. The seller is responsible for integrating their accounting system with AEAT’s platform or using intermediary software that meets Spanish XML reporting standards. Tools such as Avalara, Amavat, Taxdoo, or Datev are widely used for this purpose, as they can automatically generate and transmit compliant files.
Penalties and Compliance Risks
AEAT treats SII obligations with the same seriousness as VAT declarations. Errors or delays in reporting are penalized under the Spanish General Tax Law (Ley General Tributaria). The law allows the agency to impose fines amounting to 0.5% of the transaction value, with a minimum of €300 and a maximum of €6,000 per reporting period. In practice, however, AEAT tends to apply lower penalties if the taxpayer voluntarily corrects mistakes before receiving an official notice.
Persistent non-compliance or long-term failure to report can lead to far more severe consequences, including the revocation of your NIF and removal from the ROI/VIES registers, which effectively prevents you from trading within the EU.
At the same time, SII offers tangible benefits. Because AEAT has complete data in real time, VAT refunds are processed faster, discrepancies in filings are less likely, and the number of audit requests drops significantly. For businesses, it also means fewer administrative surprises and greater certainty that their reporting matches AEAT’s records.
Why SII Matters for Amazon FBA Sellers
In the end, the SII system is not just another bureaucratic requirement — it’s a shift toward a fully digital tax environment. For high-volume Amazon FBA sellers or those operating under REDEME, participation is both mandatory and beneficial, as it speeds up VAT processing and improves transparency. For smaller e-commerce businesses, joining SII is optional, but more and more sellers view it as an investment in accuracy, automation, and long-term compliance with Spanish tax law.
SII might sound demanding at first, but for serious Amazon FBA operators, it’s becoming an essential part of doing business smoothly and confidently in Spain’s highly digitalized tax landscape.
Amazon and VAT Responsibility in Spain
When you sell on Amazon, the platform itself is not your tax guardian. The general rule is simple: you, the seller, are responsible for VAT. Amazon provides the marketplace and logistics infrastructure, but it is not the taxable entity for your transactions.
If you sell under the FBA (Fulfilled by Amazon) or FBM (Fulfilled by Merchant) model, it’s up to you to apply the correct VAT rate, collect the tax from your customer, and remit it to AEAT — provided you hold an active NIF-IVA in Spain or in any other EU country where your goods are stored or where you carry out local deliveries.
This responsibility doesn’t go away even if you use Amazon’s invoicing features. The only partial exception is when you enable the Amazon Invoice Generation Service. In that case, Amazon generates the invoices for you, but you remain the taxable entity. You’re still responsible for ensuring the accuracy of VAT numbers, rates, and classifications.
In practice, that means you must regularly review your tax settings and make sure your invoicing system matches your VAT registrations. This is particularly important for sellers participating in Pan-European FBA, because simply storing goods in Spain — even without local sales — creates a local VAT obligation.
When Amazon Becomes a “Deemed Supplier”
Amazon acts as a “deemed supplier” only in very specific B2C situations. This happens when a non-EU seller lists products on Amazon that are already located within the European Union, or when goods are imported into the EU with a value of up to €150, handled through the IOSS (Import One Stop Shop) scheme.
In these cases, there are legally two separate supplies: one between the non-EU seller and Amazon, and another between Amazon and the end customer. VAT on the second transaction is then collected and reported by Amazon.
However, if the non-EU seller already has an active VAT number in any EU member state, Amazon does not act as the deemed supplier — the seller is fully responsible for charging and reporting VAT. The same applies to B2B transactions within the EU: if the buyer has a valid VAT number, the deemed supplier mechanism doesn’t apply, and the transaction follows the traditional VAT rules, with zero-rated intra-EU supply, a declaration in Modelo 349, and full consistency with the actual goods movement.
In short, the “deemed supplier” model is an exception, not the norm. It does not remove your obligations as an FBA seller operating in Spain.
Setting Up VAT Data Correctly in Seller Central
Your main control panel for VAT compliance is the Tax Settings section in Amazon Seller Central. This is where you enter and maintain your VAT numbers for each country where Amazon might store your inventory or where you make domestic sales.
For Spain, your VAT number should be entered in the format ES + NIF-IVA, and it must be active and visible in the VIES database. Amazon periodically verifies VAT numbers — usually every few months — using both VIES and local data interfaces. If AEAT suspends your number, your listings on Amazon Spain will automatically be hidden until your VAT registration is reactivated.
In practice, there are three elements that must always align: your valid NIF-IVA in Seller Central, your correct VAT rates assigned to product listings, and your invoice system, whether you issue invoices manually or through Amazon’s automated service.
The “VAT Services on Amazon” program can simplify your administrative work, but it doesn’t shift the legal responsibility. If something goes wrong, AEAT contacts you — not Amazon.
What Happens If You Don’t Have a VAT Number on Amazon
Not having an active NIF-IVA in a country where you store or sell goods exposes you to risks on two fronts.
On the Amazon side, you could face hidden listings, frozen payouts, or even account suspension until your VAT information is updated.
On the tax authority side, AEAT can impose administrative penalties ranging from fines for late registration and missed returns to surcharges and percentage-based penalties for unpaid VAT. Persistent non-compliance can trigger more serious consequences, such as revocation of your NIF and removal from ROI and VIES, which would effectively block you from trading within the EU’s internal market.
At the same time, AEAT’s access to data has never been broader. Under the DAC7 Directive, Amazon is required to report detailed information about sellers through Modelo 238. That means inconsistencies between your Seller Central VAT details, VIES registration, and actual stock movement are easily detected.
For growing e-commerce brands, the safest practice is to run a quarterly compliance check. Make sure your Spanish VAT number is active, confirm that your product catalogue applies the correct VAT rates, and verify that every sale generates a proper invoice.
In the world of Spanish VAT and Amazon FBA, proactivity always pays off. Staying ahead of reporting deadlines, registration updates, and system checks will save you from blocked listings, delayed payouts, and costly tax corrections later on.
The OSS System (One Stop Shop) — When It Makes Sense to Use It
How the OSS System Works
The One Stop Shop (OSS) is an EU-wide mechanism that simplifies VAT compliance for cross-border B2C sales within the European Union. It allows sellers to report and pay VAT on all distance sales to consumers in other EU countries through a single quarterly return submitted in their home country.
Once your total annual cross-border B2C sales exceed the €10,000 threshold, you must start applying the VAT rate of the customer’s country — the so-called “country of consumption.” Without OSS, you would have to register separately for VAT in each country where your customers live. With OSS, that entire process is centralized: you report everything in one declaration, and your local tax authority automatically distributes the VAT to the relevant EU tax offices.
It’s important to note that the €10,000 limit applies to the combined total of all B2C cross-border sales across the EU, not per country. It also doesn’t include your domestic sales within your own country.
Who Can Register for OSS
OSS is available to EU-based businesses that sell goods or digital services B2C to customers in other member states. Non-EU businesses can also use OSS, but only if they meet specific conditions depending on which procedure applies to them.
The system operates in three variations. The Union OSS scheme covers EU sellers who make distance sales of goods to consumers in other member states. The Non-Union OSS scheme applies to non-EU businesses that provide digital or electronic services to EU consumers. Finally, the Import OSS (IOSS) procedure is designed for cross-border sales of imported goods valued up to €150.
For EU sellers, registration takes place in the country where the business is established. Once accepted, you file a single quarterly VAT return — in euros — that includes all your eligible cross-border B2C sales across the EU.
The Advantages and Limits of OSS
The biggest advantage of OSS is operational simplicity. You only need one registration, one return, and one payment, and you can forget about dealing with multiple local VAT portals across Europe. Everything is centralized, and you can report all sales in euros, using the correct VAT rate for each customer’s country.
However, OSS comes with its own set of obligations. While you don’t have to issue local VAT invoices for every sale under the OSS regime, you must keep complete transaction records for 10 years and provide them upon request to any EU tax administration.
The system also has clear limits, especially from the perspective of Amazon FBA sellers in Spain. OSS only applies to cross-border B2C sales — meaning distance sales to consumers in other EU countries. It does not cover inventory movements, local warehouse transfers, or B2B transactions. Those must still be reported through your local VAT filings.
Why OSS Doesn’t Replace Local VAT Registrations for FBA Sellers
If you use Amazon FBA, the physical storage of your goods in Spain automatically creates a local VAT obligation, regardless of where your customers live. OSS doesn’t apply to stock movements between Amazon warehouses, nor can it be used to report intra-EU transfers of goods.
These operations must still be declared in Modelo 303 (and, where relevant, in Modelo 349) as part of your Spanish VAT compliance. In practice, that means you’ll be operating in a dual system: OSS for your cross-border B2C sales, and local VAT registrations — your NIF-IVA and periodic returns — for countries where Amazon physically stores your stock.
When managed correctly, this hybrid setup ensures that your sales remain fully compliant with AEAT’s regulations while avoiding dangerous gaps between warehouse movements and VAT reporting.
For Amazon FBA sellers expanding across Europe, OSS is a powerful tool, but not a universal solution. It simplifies cross-border sales, yet you still need local VAT registrations wherever your inventory lives. Understanding how these two systems work together is the key to staying compliant and keeping your Pan-EU FBA operations running smoothly.
Practical Steps for Amazon FBA Sellers in Spain
Check Your VAT Obligations
The first step for any Amazon FBA seller is to clearly identify where your VAT obligations arise. In Spain, the rule couldn’t be simpler: if Amazon stores your goods in a Spanish warehouse, you are required to register for VAT from the moment your first shipment arrives.
This rule is unconditional and comes directly from Article 84 of the Spanish VAT Act (Ley 37/1992), which treats the storage of goods as taxable activity carried out on Spanish territory.
It’s also worth remembering that the €10,000 EU threshold applies to the total value of all B2C cross-border sales from your country of dispatch to customers in the EU — it’s not a separate threshold per market. Once you exceed this limit, you must apply the VAT rate of the customer’s country.
If you decide to register for the OSS (One Stop Shop) system, that threshold becomes irrelevant — from the moment of registration, you apply the VAT rate of the customer’s country, regardless of turnover.
For Amazon FBA users, this makes it essential to monitor where your inventory is stored. You can do this directly from your Amazon Seller Central dashboard. AEAT may later cross-check this information against data from DAC7 reporting, so it’s important to stay consistent.
Obtain Your NIF or Appoint a Fiscal Representative
For EU-based companies, VAT registration in Spain is done through Form Modelo 036, filed with the Spanish Tax Agency (AEAT). You don’t need a Spanish bank account — AEAT accepts payments from SEPA accounts in other EU countries.
Your application must include your business registration documents, proof of identity for the company owner, and a signed power of attorney. In some cases, AEAT may also request certified Spanish translations prepared by a traductor jurado (sworn translator).
Once your documents are approved, AEAT assigns you a temporary NIF, which becomes an active NIF-IVA after verification. From then on, your number will appear in the VIES system as a valid EU VAT registration.
If your company is based outside the EU, Spanish law requires you to appoint a fiscal representative (representante fiscal). This is a local tax agent authorized to represent you before AEAT, file returns, and manage communications. The representative is jointly liable for your tax obligations, so it’s important to choose an experienced, reputable firm with proper accreditation and insurance coverage.
Set Up Invoicing and Accounting Systems
Once you receive your VAT number, you must ensure your invoicing system meets Spanish legal standards. Every invoice should include your NIF-IVA, the customer’s details, the invoice date and number, a description of the goods sold, the net amount, the applicable VAT rate, and the total VAT charged.
Amazon offers an Invoice Generation Service that can automatically issue invoices on your behalf, but the responsibility for accuracy remains entirely yours.
Unlike SII reporting, you are not required to use XML format — standard PDF or electronic invoices are fully acceptable. Just remember to store all invoices for four years, as that’s the statute of limitations for VAT obligations in Spain.
It’s highly recommended to use accounting software integrated with both AEAT and Amazon, such as Avalara, Amavat, SimplyVAT, or Taxdoo. These systems automatically import your sales and purchase data, generate Modelo 303 returns, and help you maintain compliance with minimal manual work.
Consider Using the SII System
Spain’s Suministro Inmediato de Información (SII) system enables real-time electronic reporting of invoices to AEAT. It is mandatory for large businesses with an annual turnover above €6 million, as well as for companies in the REDEME refund scheme or members of VAT groups.
If you want to join voluntarily, you can do so by indicating “Alta en el SII” on your Modelo 036 form. Once registered, you’ll report all invoice data in XML format within four working days of issuing or receiving each invoice.
SII greatly simplifies reporting: you no longer need to keep paper VAT ledgers or submit the annual Modelo 390, and VAT refunds are usually processed faster. While most Amazon FBA sellers aren’t required to participate, joining SII can be a smart move if your business is growing quickly and you want a more automated, transparent system.
Stick to a Reporting Schedule
The Spanish VAT system is strict about deadlines, so consistency is key. Modelo 303 must be submitted quarterly — by April 20, July 20, October 20, and January 30 for the fourth quarter.
If you choose direct debit, your return must be filed by the 15th of the month to allow AEAT to process the payment automatically.
In addition to Modelo 303, some sellers must also file Modelo 349, which reports intra-EU transactions. This is usually done monthly, unless your total intra-EU turnover (WDT/WNT) remains below €50,000 per quarter, in which case you can file quarterly.
Finally, Modelo 390, the annual VAT summary, must be submitted unless you participate in SII or REDEME, both of which exempt you from this requirement.
Keep Track of VAT Rate Updates
Spain frequently updates its VAT rates, especially for food and energy products. As of January 2025, new rates apply: 4% for basic goods and olive oil, and 10% for seed oils and pasta. The 21% standard rate remains in place for most items, while reduced rates apply selectively.
Non-alcoholic drinks, luxury goods, and dietary supplements remain subject to higher rates. AEAT maintains an official database called Base de Datos de Tipos de IVA, which accounting firms and software providers use to stay current — and so should you.
Update Your VAT Data in Amazon Seller Central
Finally, make sure your Spanish VAT number is correctly entered in the Tax Settings section of Amazon Seller Central in the format ES + NIF-IVA, and that it appears as active in VIES.
Amazon periodically verifies VAT numbers against VIES (every few months), but it doesn’t check your status directly with AEAT — that’s your responsibility. Any mismatch between your Amazon data, AEAT registration, or tax filings can lead to withheld payouts, hidden listings, or even account suspension.
Also remember that under DAC7, Amazon shares detailed information about sellers and transactions with AEAT using Modelo 238. If your Seller Central data differs from your registration records, AEAT will detect it easily.
Regularly checking your VAT number’s status, keeping your data updated, and verifying invoice accuracy are simple habits that can prevent serious disruptions. In the world of Spanish VAT and Amazon FBA, these proactive steps are the difference between smooth operations and costly setbacks.
Summary
Selling through Amazon FBA opens enormous opportunities for growth across Europe — but it also brings real responsibilities, especially when it comes to taxes. Spanish VAT (IVA) is not something you can afford to overlook. Spain’s tax administration is among the strictest in Europe when it comes to monitoring e-commerce sellers, and even small delays or missing registrations can lead to serious financial consequences.
When VAT in Spain Becomes Mandatory
You are required to register for VAT in Spain in two main cases. The first is when your goods are stored in a Spanish Amazon warehouse, even if you haven’t made a single local sale. The second is when you exceed the €10,000 EU-wide B2C sales threshold for cross-border distance sales within the EU.
For non-EU sellers, the obligation starts from your first sale or the moment you begin storing goods in Spain. In these cases, Spanish law also requires appointing a local fiscal representative. Even if you’re registered in the OSS (One Stop Shop) system, it doesn’t exempt you from local VAT registration in countries where Amazon physically holds your stock.
How to Avoid Fines and Penalties
The Spanish Tax Agency, AEAT, is highly efficient at monitoring online sellers. To stay compliant, follow a few essential rules. Register for VAT before you start selling. File your VAT returns on time — including Modelo 303, 349, and, when required, 390. Keep your invoices for at least four years, and make sure your data in Amazon Seller Central is always up to date.
If you miss a deadline, AEAT applies what’s known as recargo por declaración extemporánea — a surcharge of 1% per month for up to 12 months, and 15% plus interest after a year. If the tax authority launches an audit and finds unpaid VAT, the penalty can range from 50% to 150% of the unpaid amount.
The safest approach is to stay proactive. File corrections or supplementary returns before AEAT issues a formal notice. That simple step can significantly reduce or even eliminate penalties.
Also, keep an eye on regulatory updates. From January 2025, Spain has new VAT rates for food products, and upcoming changes to the SII and DAC7 systems will make tax data even more transparent. This means inconsistencies will be detected almost automatically — another reason to stay vigilant.
Building a Compliant FBA Process
If you view selling through Amazon FBA in Spain as part of your long-term strategy, you’ll need to establish clear internal processes to ensure full tax compliance.
Start by registering and obtaining your NIF-IVA, or, if you operate from outside the EU, appointing a fiscal representative. Next, make sure your invoicing system is integrated with both AEAT and Amazon, so every transaction is recorded and reported correctly. Automating your VAT filings with AEAT-compatible accounting tools will make life much easier.
Finally, keep your VAT details in Amazon Seller Central up to date and check your registration status in VIES regularly. This combination of automation, regular monitoring, and proper integration will keep you fully compliant and protected against unnecessary risks.
Full VAT compliance doesn’t just protect you from fines — it also helps your business grow. Sellers who operate transparently and on time enjoy smooth payouts, uninterrupted listings, and stronger reputations on the platform. Amazon rewards consistency, and compliance is the foundation of long-term success.
Trust the Experts — We’ll Help You Get Registered in Spain and Across the EU
If you’re planning to expand your Amazon FBA business into Spain or other EU markets, you don’t have to handle the tax side alone. Our team specializes in VAT registration, fiscal representation, and OSS support across Europe.
We’ll help you register correctly, integrate your accounting systems, and stay compliant with AEAT’s strict requirements. With expert guidance, you can focus on what really matters — growing your sales, not managing paperwork.
Get in touch with us, and we’ll guide you through every step — from registration to reporting — helping you build a strong, compliant foundation for your brand on the Spanish Amazon marketplace.
