The autónomo's VAT record books, one by one

Accounting and record books are not the same duty

They are easy to confuse, because both are born from the same invoices, but they are separate duties, under separate rules and with separate scope. Full accounting under the Commercial Code is only required by article 68.2 of the Income Tax Regulation from someone carrying on a business activity whose profit is determined under the normal form of direct assessment. The VAT record books this guide explains, by contrast, are kept by any autónomo with VAT liable activity, whether or not that accounting duty applies, because they come from the VAT Regulation and not from anyone's accounting regime.

Article 68.10 of the Income Tax Regulation closes the question from the other side: taxpayers other than those in paragraph 2 must keep the record books even when they voluntarily keep accounts under the Commercial Code. Deciding to keep full accounts out of preference, on a bank's advice or to apply for financing does not release anyone from the record books.

The good news is that nothing has to be typed twice. Article 62.3 of the VAT Regulation allows the books or registers, including electronic ones, already kept for other tax or accounting duties to be used for VAT purposes, as long as they meet the requirements of the Regulation itself, and article 12 of Order HAC/773/2019 says the mirror image for the income tax books. One system can serve both duties at once; what it cannot do is leave out a field either of them requires.

The four VAT record books

Article 62.1 of the VAT Regulation sets out four record books as the general rule: issued invoices, received invoices, investment goods, and certain intra-EU operations. The first two are kept by practically every active autónomo; the other two only fill up when the activity produces the specific facts that trigger them, and we come back to those below.

Article 62.2 takes three special regimes out of that general duty, subject to whatever their own rules provide: the simplified regime, the agriculture, livestock and fishing regime, and the equivalence surcharge regime. Occasional supplies of new means of transport by the persons referred to in article 5.uno.e) of the VAT Act are also outside. Beyond those listed cases the duty does not depend on the size of the business or on turnover: an autónomo who invoices very little keeps exactly the same books as one who invoices a lot.

There is a practical rule almost nobody knows, and it matters to anyone with a shop and a workshop, or two outlets: article 62.4 allows a person who owns several establishments to keep the books at each of them, recording separately the operations carried out from each place, provided the summary entries of all of them are transferred to the general record books, which are kept at the tax domicile. What does not exist is the option not to consolidate: the tax domicile always holds the complete books.

There is also a little known door: article 62.5 allows the tax agency's Tax Management Department to authorise, after whatever checks it sees fit, replacing these books with different recording systems, or accepting summary entries on conditions other than those in article 63.4, where the commercial or administrative practices of the sector, or the technical conditions under which invoices are issued, make it hard to state those particulars. Those authorisations are revocable at any time; they are not a right anyone exercises on their own initiative.

What every entry of the issued invoices book carries

Article 63.1 requires an issued invoices record book to be kept and preserved, recording in it, duly separated, the total of those documents. Article 63.3 sets out the content of each entry: invoices are recorded one by one, stating the number and, where applicable, the series; the date of issue; the date the operations were carried out, if different from the previous one; the name, company name or full denomination and the tax identification number of the recipient; the taxable base determined under articles 78 and 79 of the VAT Act; where applicable, the rate applied, with the option of adding the words «IVA incluido»; the VAT amount; and whether the operation follows the cash accounting special regime.

From the very first invoice issued, every document is recorded with that data. A flawless invoice does not replace the entry: they are two different things, the document handed to the customer and the entry that registers it, and the duty in article 63 falls on the second.

Article 63.6 adds a rule that is often forgotten: credit notes and other corrective invoices under article 15 of the Invoicing Regulation are recorded separately, stating the number, the date of issue, the identification of the supplier, the taxable base, the rate and the VAT amount. Separately means in their own entry, not by editing by hand the entry of the original invoice, which must go on telling the story of what was issued on the day.

The summary entry: when you may group your daily tickets

Article 63.4 allows the individual entry to be replaced by summary entries stating the date the invoices were issued, the global taxable base for each rate, the rates, the global VAT amount of invoices numbered consecutively and issued on the same date, and the first and last numbers of those invoices. To do that, two requirements have to be met simultaneously: that identifying the recipient was not compulsory on the invoices issued, under the Invoicing Regulation, and that the chargeable event of the documented operations took place within the same calendar month.

It pays to read slowly what the entry groups and what the month conditions. The entry groups invoices numbered consecutively and issued on the same date: in practice it is the day's summary. The same calendar month is the requirement attached to the chargeable event of those operations. That is why there is no quarterly summary entry, and none that swallows a whole month in one go, and why the first and last numbers have to be a genuine consecutive run, with no gaps papered over by eye.

This is exactly what an online shop, a bar or a retail counter issuing dozens of simplified invoices a day needs. The full invoice issued that same day to a business customer, with its tax number, stays out of the summary entry and is recorded individually: on that one, identifying the recipient was compulsory, so the first of the two requirements fails. Article 63.4 closes with a rule that helps when you sell goods at different rates: it is equally valid to record one and the same invoice in several consecutive entries when it includes operations taxed at different rates.

The received invoices book and the order of receipt

Article 64.1 requires consecutive numbering of every invoice, accounting voucher and customs document for goods acquired or imported and services received in the business; that numbering may use separate series where objective reasons justify it. Article 64.4 requires them to be recorded one by one, stating their reception number, the date of issue, the date the operations were carried out if different and stated in the document, the name and tax identification number of the person obliged to issue it, the taxable base and, where applicable, the rate and the VAT amount. The reception number is yours, not the supplier's: it is the order in which invoices reach your business.

Article 69.3 decides when each one goes in: received invoices are recorded in the order in which they are received, and within the settlement period in which their deduction is due. What governs is not the date printed by the supplier but the receipt and the period in which that input VAT falls to be deducted, which is what later supports every line of deductible expenses.

Received invoices also have their own summary entry, different from the one for issued invoices and with amount limits the other does not have. Article 64.5 allows a global summary entry of invoices received on the same date, with the first and last numbers assigned by the recipient, the global sum of the taxable base for each rate and the global VAT amount, provided they come from a single supplier, that the combined total of the operations does not exceed 6,000 euros excluding VAT, and that none of the grouped invoices exceeds 500 euros excluding VAT.

Investment goods and intra-EU operations

Not everyone keeps the investment goods record book. Article 65.1 requires it from taxable persons who have to carry out the adjustment of deductions for investment goods under articles 107 to 110 of the VAT Act, which is the typical position of someone operating under the pro rata rule or whose deductible percentage changes over the years following the purchase. Goods are registered individually and, for each one, the date it came into use, the final annual pro rata and the annual adjustment of deductions, where applicable.

The book of certain intra-EU operations is even more specific: article 66.1 lists exactly what goes into it, and it is not ordinary intra-EU trade. It is three things: sending or receiving goods for the expert reports or work referred to in article 70.uno.7.º b) of the VAT Act; transfers of goods and intra-EU acquisitions under article 9.3.º and article 16.2.º; and sending or receiving goods covered by a call-off stock arrangement under article 9 bis.

Selling to a French company or buying from a German supplier does not, on its own, generate any entry here: those operations go to the issued and received invoices books and, where applicable, to the modelo 349. Anyone who does carry out one of the three operations in article 66.1 has a short deadline of its own: article 69.4 requires them to be recorded within seven days from the moment the dispatch or transport of the goods begins.

How they are kept and how long you must keep them

The VAT Regulation imposes no particular software and no closed official format on anyone outside the electronic reporting system, but it does impose form. Article 68.1 requires the books to be kept, whatever the procedure used, clearly and accurately, in date order, with no blank spaces and no interpolations, erasures or crossings out, correcting any errors or omissions immediately after they are noticed, and stating values in euros, converting them where the invoice was issued in another currency. Article 68.3 adds that pages must be numbered consecutively, and articles 63.2 and 64.3 expressly accept entries made on separate sheets, which must afterwards be numbered and bound consecutively to form the book.

Article 67 explains the point of all this: the books must make it possible to determine precisely, in each settlement period, the total VAT charged to customers, the total input VAT and the deductible amount, and the situation of the goods in the intra-EU operations book until the chargeable event occurs. If your system cannot answer that in a minute, the problem is not untidiness, it is compliance.

There are two retention periods, and mixing them up helps nobody. Article 30.1 of the Commercial Code requires a business owner to keep the books, correspondence, documentation and vouchers of the business, duly ordered, for six years from the last entry made in the books, and its paragraph 2 makes clear that ceasing to trade does not release anyone from that duty. Article 68.1 of the Income Tax Regulation, for its part, requires vouchers and supporting documents to be kept for the maximum limitation period.

Deadlines: when it all has to be recorded

Article 69.1 sets the general rule: operations subject to registration must be recorded in the books at the time the tax on them is settled and paid or, in any event, before the legal deadline to do so voluntarily expires. That deadline comes from article 71.4 of the same Regulation: the first twenty calendar days of the month following the quarter, except for the return for the last period of the year, which is filed in the first thirty calendar days of January. Running that deadline out with the book still open, the 20th in the first three quarters and 30 January in the last one, is not untidiness: it breaches article 69.1 before the modelo 303 is even filed.

Article 69.2 is stricter in one specific case: operations for which no invoice is issued must be recorded within seven days from the moment they are carried out or the relevant document is issued, provided that period is shorter than the general one, which it usually is. It is a rule about operations without an invoice, not a seven day deadline for ordinary invoicing.

Anyone inside the immediate supply of information system lives on another calendar. Article 62.6 requires the books to be kept through the tax agency's electronic portal by those whose settlement period is the calendar month under article 71.3, that is, those who exceeded 6,010,121.04 euros of turnover in the previous year, those registered for monthly refunds and VAT groups, among other cases. Their deadlines come from article 69 bis: four calendar days from the issue of the invoice, eight if it is issued by the recipient or a third party, and always before the 16th of the month following the chargeable event. A typical autónomo is not in the SII, and may opt in under article 68 bis if it suits them.

The income tax books under direct assessment

The VAT books are not the only ones. Article 68 of the Income Tax Regulation imposes its own record books, and which ones depends on the type of activity and the form of assessment. Someone carrying on a business activity that is not commercial in nature under the Commercial Code keeps three books, under article 68.3: sales and income, purchases and expenses, and investment goods. Someone carrying on a business activity under the simplified form of direct assessment keeps those same three, under article 68.4. And someone carrying on a professional activity under direct assessment, in either of its two forms, keeps four, under article 68.5: income, expenses, investment goods, and advances of funds and disbursements on behalf of clients, that last one exclusive to professionals.

How they are kept is developed by Order HAC/773/2019. Its article 2.2 recognises for income tax a daily summary entry equivalent to the VAT one, with the first and last invoice numbers and the global base per rate, for invoices where identifying the recipient is not compulsory and whose chargeable event falls in the same calendar month. Its article 3.3 repeats for purchases the global summary entry from a single supplier with the 6,000 and 500 euro limits. Article 9.1 requires them to be kept clearly and accurately, in date order, and totalled in every case by calendar quarters and years; article 9.4 requires separate books for each activity.

The deadline is different too. Article 10.1 of the Order requires everything to be recorded before the deadline to declare and pay the instalment payments expires, that is, the modelo 130; article 11 requires errors to be corrected immediately after they are noticed, through an entry that makes it possible to determine, for each quarter, the whole of the income and expenses once corrected.

How kontora handles it

kontora builds the issued invoices record book and the received invoices record book from the invoices you issue and the expenses you record, and applies the article 63.4 summary entry only where it genuinely fits: it groups consecutive runs of invoices with no identified recipient issued on the same date and with the chargeable event in the same month, and leaves everything else recorded one by one. The boxes of the 303 come from those books without anyone copying a figure by hand, and professionals also get their book of advances of funds and disbursements. You can download them as a spreadsheet or as CSV whenever you like, including if you cancel: the full export is never blocked. Filing the return is still your move.

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