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Amazon and marketplaces: tax

Amazon seller fees reverse charge: Spain VAT return 303 and 349

Reviewed on 9 min readConsult GlobalLex team

If your Amazon fee invoice shows no Spanish VAT, it is not a mistake: you account for the VAT yourself under the reverse charge (inversión del sujeto pasivo). For a company on the Spanish mainland, the fees go in boxes 10/11 and 36/37 of Form 303 (modelo 303) and on Form 349 (modelo 349) with key I. If your company is in the Canary Islands, you self-assess IGIC on Form 420 (modelo 420) and do not file Form 349.

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The problem

You open the monthly marketplace fee invoice and see a taxable amount but no VAT. It is natural to wonder whether something is missing, whether you should ask for a corrected invoice, whether you can deduct anything, and how to record it without throwing out your quarterly VAT return.

The explanation is that the supplier is established in another EU Member State and is providing a service to a business. Business-to-business services are treated as supplied where the recipient business is established (art. 69.Uno.1.º LIVA). If your company is on the Spanish mainland, the service is therefore treated as supplied in Spain. Because the supplier is not established here, the person liable for the VAT is you, the recipient business (art. 84.Uno.2.º a) LIVA). That is why the invoice carries no Spanish VAT.

The fact that the marketplace issues the invoice does not change who is liable: it is still the seller. What does change is that you must now reflect the transaction in your own returns, and that is where most mistakes happen.

Who is affected

  • Spanish limited companies (sociedades limitadas) based on the mainland that sell on Amazon and receive fee invoices from a supplier established in another EU Member State.
  • Spanish limited companies based in the Canary Islands that receive the same invoices, where the applicable tax is IGIC and not VAT.
  • Foreign entrepreneurs who have set up a company in Spain and have not yet filed their first return containing this type of invoice.
  • Bookkeepers who have to reconcile the monthly fee invoice with Form 303 and Form 349 every period.

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Step by step

  1. Work out whether your company is subject to VAT or to IGIC

    Everything depends on territory. For VAT purposes the Canary Islands are outside the territory of the Community (art. 3.Dos.1.º b) LIVA), so a Canarian company does not follow the Form 303 and Form 349 route.

    If your company is on the mainland or in the Balearic Islands, follow steps 2 to 5 and step 7. If it is in the Canary Islands, go straight to step 6.

  2. Accept the invoice without VAT and check its details

    The absence of Spanish VAT on the invoice is not a defect. What you should check is that your company name and tax number, the period and the taxable amount are correct. You will use that taxable amount to calculate the VAT yourself.

    Do not ask the marketplace to add Spanish VAT. Under the rules described above, the VAT is something you account for in your own return.

  3. Report the output and deductible VAT on Form 303 (modelo 303)

    On Form 303, the taxable amount and the VAT go in boxes 10 and 11 (intra-Community acquisitions of goods and services), as output VAT. The corresponding VAT, if you are entitled to deduct it, goes in boxes 36 and 37 (deductible VAT on intra-Community acquisitions of goods and services other than investment goods). See the 2026 instructions for Form 303 and the form with its box labels.

    Boxes 12 and 13 are for reverse-charge transactions other than those reported in boxes 10 and 11, for example purchases from a supplier established outside the EU. Fees charged by a supplier established in the EU do not go there.

  4. Include the transaction on Form 349 (modelo 349) with key I

    The same invoice is reported on Form 349 as an intra-Community acquisition of services located in Spanish VAT territory and supplied by a business established in another Member State. This is key I (art. 79.1.4.º RIVA). The instructions for Form 349 explain how to complete it.

    If you also sell from stock held in other EU countries, see our guide on Amazon Pan-EU FBA VAT for Spanish sellers, because those transfers are reported differently.

  5. Check that you are registered in the ROI

    To report this kind of transaction you need to appear in the Register of Intra-Community Operators (Registro de Operadores Intracomunitarios, ROI). Those required to register include businesses that receive services from non-established suppliers under the reverse charge (arts. 3.3 and 25 RGAT). Registration is requested with Form 036 (modelo 036).

    If you have not done this yet, our guide to the Spanish intra-community VAT number and ROI registration walks you through the process.

  6. If your company is in the Canary Islands: IGIC under the reverse charge on Form 420

    A Canarian company that receives this invoice self-assesses IGIC (the Canary Islands indirect tax) under the reverse charge on Form 420 (modelo 420), which is filed with the Canary Tax Agency (Agencia Tributaria Canaria, ATC) (art. 19.1.2.º a) Ley 20/1991). It does not file Form 349 for these invoices, because the Canary Islands are not EU VAT territory, and it does not need the ROI for them.

    Check the specific boxes of Form 420 in the ATC help program before filing, because they depend on the version in force. The ATC page for Form 420 and the Form 420 instructions are the places to look.

  7. Reconcile every month

    The control check is simple. For a mainland company, the total of the monthly fee invoices should match boxes 10/11 of Form 303 and the key I entries on Form 349 for the same period.

    Doing this each month, rather than at the end of the quarter, means you spot a missing invoice or a wrongly placed box while there is still time to file on time.

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Deadlines

Form 303 quarterly (mainland), first to third quarters
From 1 to 20 April, July and October, in calendar days. If the last day is not a working day, the deadline moves to the next working day. · source
Form 303, fourth quarter
From 1 to 30 January. In 2027, 30 January is a Saturday, so the deadline moves to 1 February 2027; confirm this when the 2027 calendar is published. · source
Direct debit of the Form 303 for the third quarter of 2026
Until 15 October 2026. The general deadline for the third quarter ends on 20 October 2026. · source
Form 349
Monthly, within the first 20 days of the following month (for July, until 20 September). Quarterly if neither in the quarter nor in the four previous quarters did intra-Community supplies and services exceed €50,000. The last period of the year runs until 30 January. · source
Form 420 quarterly (Canary Islands)
From 1 to 20 April, July and October; for the fourth quarter, from 1 to 31 January. With direct debit, the first 15 days (in January, the first 20). If the day is not a working day, the deadline moves to the next working day. · source

Common mistakes

Entering the transaction in boxes 12 and 13 of Form 303 instead of boxes 10 and 11.

Boxes 12/13 are for reverse-charge transactions other than those in boxes 10/11. Fees from a supplier established in the EU go in boxes 10/11 as output VAT and in boxes 36/37 as deductible VAT, as the Form 303 instructions say.

Not reporting the self-assessed VAT because the invoice does not show it.

Calculate the VAT yourself from the taxable amount on the invoice. Failing to report it is an infringement under art. 170.Dos.4.º LIVA. Even if the deduction offsets the VAT, the obligation to declare it still exists.

Forgetting Form 349 with key I in a mainland company.

Include the invoice on the Form 349 for the relevant period. If the company is Canarian, the opposite mistake is filing a Form 349 that does not apply, because the Canary Islands are not EU VAT territory.

Filing Form 303 or Form 390 in a Canarian company.

Canarian companies file Form 420 and Form 425 (modelo 420 and modelo 425) with the Canary Tax Agency, not with the Spanish Tax Agency (AEAT), for their operations in the Canary Islands.

Missing the deadline and only noticing when you reconcile the quarter.

Review the fee invoices every month and file before the deadline ends, remembering that direct debit closes earlier. If you have already filed late, take advice on what to expect before you correct anything.

30-second mini diagnostic

Tick your answers: the list is built in your browser and not stored.

Do you sell to consumers in other EU countries?
Do you hold stock in warehouses outside Spain (e.g. FBA)?
Is your company in the Canary Islands?
Do you import goods from China?
Full diagnostic

Indicative result based on general rules; it does not replace advice on your case.

Frequently asked questions

Can I deduct the VAT I charge myself on the fees?

If your business activity gives you the right to deduct, the VAT is reported as deductible in boxes 36/37 of Form 303. If you carry out operations both with and without the right to deduct, the amount you can deduct depends on the pro rata rules (arts. 102 and 104 LIVA).

Do I need to file Form 349 if the Amazon fees are my only EU transaction?

For a mainland company, yes: the fee invoice is reported with key I, and receiving services from a non-established supplier under the reverse charge is one of the cases that requires ROI registration. For a Canarian company, no Form 349 is filed for these invoices.

My company is Canarian and has an ROI registration. Does that mean I file Form 349 for the fees?

No, not for those invoices. The Canary Islands are not EU VAT territory, so the fees are handled with IGIC under the reverse charge on Form 420. The ROI is a register for businesses established in the Spanish VAT territory, that is, the mainland and the Balearic Islands.

Does anything change if the marketplace issues the invoice on my behalf?

The person liable for the tax does not change: it is still the seller, under art. 84 LIVA. The exception is the digital interface rule in art. 8 bis LIVA, which treats the marketplace as if it bought and resold in certain cases. A mainland company is established in the EU, so the case concerning sellers not established in the Community does not apply to it. For a Canarian company, whether art. 8 bis b) applies is not confirmed and should be checked before you assume anything.

What should I do if the supplier has no EU VAT number?

According to the Spanish Tax Agency, a purchase from an EU supplier that is under a VAT exemption scheme and has no VAT number is not an intra-Community acquisition taxable in Spain. Do not assume that applies to your marketplace: check which tax identification appears on the invoice.

When is the Form 303 for the third quarter of 2026 due?

The general deadline ends on 20 October 2026. If you pay by direct debit, the deadline is earlier: until 15 October 2026.

Official sources

Consult GlobalLex team

Tax, accounting and legal advisers for Amazon and marketplace sellers, foreign founders and Canary Islands companies in Spain. Registered social collaborator of the Spanish Tax Agency (AEAT) and Social Security (TGSS).

Drafted with AI assistance and checked, fact by fact, against the official sources cited. Reviewed on 10 October 2026.

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