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Amazon and marketplaces: tax

DAC7 Amazon Spain seller reporting: what you must do

Reviewed on 9 min readConsult GlobalLex team

If you sell on Amazon or another marketplace, you do not file Form 238 (modelo 238): the platform does. Your part is to give the platform your details when it asks for them, and to check that what you declare to the Spanish tax authorities matches the sales the platform reports.

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The problem

Many sellers first hear about DAC7 from an email in which the platform asks for identification or tax details, or from a news story about tighter control of online sales. The usual reaction is alarm. Do I have to file something? Will I be fined? Do the tax authorities already know everything I sell?

The short answer is that the platform reports, not the seller. The platform operator required to report information is the one that files Form 238 (modelo 238) with the sellers' data. That duty comes from the 25th additional provision of the General Tax Act (Ley General Tributaria, LGT), added by Law 13/2023. The seller is only required to supply their details so that the platform can carry out its due diligence.

The real risk for a seller is not a filing of their own but whether the figures match. The Spanish tax authorities (Agencia Tributaria, AEAT) receive your gross sales through this route, and that information can be compared with what you have declared in your self-assessment returns. If there are unexplained differences, the usual result is a request for information.

That is why this guide on DAC7 and Amazon seller reporting in Spain concentrates on what you can control: the quality of the data you give the platform, the reconciliation of your sales, and a calm response if the tax authorities write to you.

Who is affected

  • Amazon and other marketplace sellers, whether self-employed or companies, who sell goods through the platform.
  • Foreign entrepreneurs with a company or business activity in Spain who use marketplaces to sell.
  • Companies and self-employed sellers in the Canary Islands who sell on marketplaces and declare IGIC (the Canary Islands indirect tax) to the Canary Islands Tax Agency (Agencia Tributaria Canaria, ATC). Whether Form 238 applies to your specific case should be checked, because the sources behind this guide do not set it out.
  • Sellers with very low activity, who may be excluded from the platform's report if they stay below the threshold set by the rules (explained in the steps).

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Step by step

  1. Confirm that you do not have to file Form 238

    Form 238 (modelo 238) is filed by platforms, under Order HAC/72/2024. As a seller you do not file or sign anything on this form. What you do have is a duty to cooperate: give the platform the details it asks for so that it can identify you correctly.

    If you receive a request for data, check that it genuinely comes from the platform through your seller account, and do not reply through doubtful links.

  2. Give the platform complete and consistent data

    Supply what the platform requests using the same tax identity under which you file your returns: the same company or personal name, the same tax ID (NIF) and the same address that appear in your tax filings. An inconsistency in those details makes any later explanation to the tax authorities harder.

    If you are a company, also check that the seller account details belong to the company and not to the individual who manages it.

  3. Check whether you could be excluded

    The rules leave out a seller who, in the period, made fewer than 30 sales of goods and no more than €2,000 in total (annex to Royal Decree 117/2024). If your volume is clearly below that, the platform is unlikely to report your data. Even so, not being reported does not release you from declaring your sales: your tax treatment does not change.

    If you are close to those limits, review the figures for the period carefully before assuming anything.

  4. Match the platform's gross sales to your tax returns

    Download the platform's sales and VAT transaction reports and classify each line by country of departure and arrival, type of transaction, and whether the buyer is a business or a private individual. Then compare the totals with what you have declared. For a company established in mainland Spain, for example, domestic sales go in boxes 01 to 09 of Form 303 (modelo 303, the quarterly VAT return), exempt intra-EU supplies in box 59, and distance sales taxed at destination in box 123 (see the Form 303 layout).

    If you sell to consumers in other EU countries, also see how the threshold and the one-stop shop (OSS) scheme fit together in our guide EU distance selling threshold of 10,000 euro: Spain OSS guide. If you are based in the Canary Islands, the reconciliation is done against IGIC and Form 420 (modelo 420) filed with the ATC, not against Form 303.

  5. If you find differences, correct them before anyone asks

    If you discover that you declared less than you sold, putting it right on your own initiative, before any request from the authorities, is far cheaper than waiting. Article 27 of the General Tax Act provides for a surcharge of 1% plus 1% for each full month of delay, with no penalty and no late-payment interest for up to 12 months. After that, the surcharge is 15% plus late-payment interest.

    Be careful: once a formal request exists, this route is closed and what follows is an assessment and a possible penalty.

  6. Prepare for a possible request for information

    The fact that the information reaches the tax authorities does not mean a request will follow, but it is sensible to be ready. Keep the platform reports, your invoices and the reconciliation between sales, returns and credit notes. If you are a company, the notification will arrive electronically, so someone should check the DEHú (Dirección Electrónica Habilitada única, the single electronic notification mailbox) regularly.

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Deadlines

Filing of Form 238 by the platform (not by the seller)
During January of the year following the tax year (art. 54.6 RGAT). For the 2025 tax year the deadline ended on 2 February 2026. · source
Replying to a request for information from the tax authorities
Not less than 10 days from the day after notification (art. 55.2 RGAT); days that are not qualified are working days (hábiles). · source
Compulsory electronic notification that is not opened
It is deemed rejected once 10 calendar days (días naturales) have passed since it was made available, and the time to reply runs regardless (art. 43.2 Law 39/2015). · source
Correcting undeclared sales on your own initiative, without a prior request
Surcharge of 1% plus 1% for each full month of delay; no penalty and no interest for up to 12 months; 15% plus late-payment interest after 12 months (art. 27 LGT). · source

Common mistakes

Believing that the seller has to file Form 238.

Remember that the platform files it. Your obligation is to give the platform truthful and complete data, and to keep your own tax returns in order.

Ignoring the platform's requests for data, or replying with details that differ from your real tax details.

Reply inside the seller account itself, using the same tax identity you use in your returns. Inconsistent data later creates discrepancies that are hard to explain.

Not comparing the platform's gross sales with what you declared for VAT or IGIC.

Reconcile the transaction report with your self-assessment returns on a regular basis, separating sales, returns and stock transfers. It is the most direct way to anticipate any difference.

Thinking that if the platform does not report your sales because you are below the threshold, you do not have to declare them.

The exclusion affects only the platform's report. Your sales remain taxable and you must declare them in the usual way.

Not opening the tax authorities' electronic notifications, hoping this stops the procedure.

Check the DEHú regularly. If you do not access it, the notification is deemed rejected after 10 calendar days and the time to reply keeps running. The email alert is for information only.

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

Frequently asked questions

Can the tax authorities fine me because of DAC7?

The sources consulted for this guide do not set out a specific DAC7 penalty for sellers, so each case should be checked before anything is assumed. What is certain is that if the sales reported do not match what you declared, you can be asked to explain the difference. Ignoring a request for information is a serious infringement under article 203 of the General Tax Act.

What happens if I do not give the platform my details?

The sources for this guide do not detail the specific consequences of failing to provide due diligence data, so it is worth checking with the platform itself and with your adviser. In any case, refusing to provide them does not stop your sales from being taxed.

Do the tax authorities see everything I sell on the marketplace?

They receive the gross sales that the platform reports through Form 238. That figure can be compared with your tax returns, which is why it matters that the two match.

I run a company with few sales. Will I still be reported?

A seller with fewer than 30 sales of goods and no more than €2,000 in the period is excluded, according to the annex to Royal Decree 117/2024. If you exceed either of those two limits, your data may be reported.

Does anything change if my company is in the Canary Islands?

Your indirect tax is IGIC, which is declared to the Canary Islands Tax Agency (ATC) on Form 420 (modelo 420) and its annual summary, Form 425 (modelo 425), not on Form 303 or Form 390. Whether Form 238 covers your company specifically is not made clear by the sources for this guide, so confirm it before deciding anything.

What should I do if I receive a request about my online sales?

Note the date on which the notification was made available, as shown on the DEHú receipt rather than on the alert email, and count the period from the following day. If you need more time, article 91 of the General Taxation Procedure Regulations allows you to ask for an extension of up to half of the period, provided you ask before the last three days.

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 8 October 2026.

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