FISCAL SOLUTIONS...

Does a QR code have to be present if there are no real-time receipts (invoices, no-Verifactu) in the new fiscalization system in Spain?

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Summary
Yes, the QR code is a mandatory requirement for both Verifactu and non-Verifactu systems that must be presented on receipts (invoices). If the QR is scanned, the AEAT will know if it has been generated by a Verifactu (which will have sent the corresponding billing record) or a No Verifactu (which will not have sent it and must keep it locally), responding accordingly.
Content

If we consider the purpose of the QR code, we can say that through the QR, the receipt (invoice) is not sent to the AEAT; it is only checked whether its corresponding billing record is in the possession of the AEAT or not—in the case of a SIF Verifactu; in the case of a SIF No Verifactu, it serves to record this data that could be used for a possible future comparison by the AEAT and control purposes.

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