Spanish IVA invoice for eSIM data — what every Spanish business needs
Why most travel-eSIM apps fail Spanish VAT compliance, and exactly what a valid IVA invoice for eSIM data must contain.
Key facts (30-second read)
- 1.A Spanish company expensing mobile data needs a complete invoice with 21% IVA (Spanish VAT) to deduct that VAT on its quarterly Modelo 303 return.
- 2.Most international travel-eSIM apps (Airalo, Holafly, Saily, Nomad) cannot issue Spain-compliant invoices — they have no Spanish tax presence and no CIF, which invalidates the buyer's VAT deduction.
- 3.eSIM Teams operates under a Spanish limited company (CIF + Madrid registered office). Every invoice meets Reglamento de Facturación (RD 1619/2012) requirements.
- 4.For EU B2B clients outside Spain, we apply reverse-charge VAT automatically — your intra-EU VAT ID is validated against VIES at signup.
- 5.Invoices download as PDF from the dashboard or arrive monthly by email — ready for your accountant.
What counts as a "complete" IVA invoice in Spain
Spanish IVA is neutral in B2B: the VAT a business pays (IVA soportado) is deducted from the VAT it charges its own customers (IVA repercutido). To deduct input VAT, Spanish tax authorities require a complete invoice meeting Royal Decree 1619/2012 — the Spanish Invoicing Regulation. Without one, that 21% is a real, unrecoverable cost.
What a valid Spanish invoice must contain
Per RD 1619/2012, a complete invoice must include all of the following:
- ·Consecutive invoice number and series (no gaps)
- ·Issue date, and if different, the date the service was rendered
- ·Issuer details: full company name, Spanish CIF/NIF, registered address
- ·Recipient details: company name, VAT ID, address
- ·Specific description of the service (generic "services" lines are rejected)
- ·Tax base (amount before VAT)
- ·Applicable VAT rate: standard 21%, reduced 10%, super-reduced 4%, or exempt
- ·VAT amount charged, expressed in euros
- ·Total invoice (tax base + VAT)
If any of these fields are missing — especially the Spanish CIF of the issuer — the tax authority can reject the input VAT deduction on audit. In practice, Spanish accountants reject those receipts upfront to avoid the risk entirely.
Why international eSIM apps can't give you a valid invoice
Major travel-eSIM platforms operate from Singapore (Airalo), Hong Kong (Holafly), or similar offshore jurisdictions. They have no Spanish tax presence, which means they cannot issue invoices with a Spanish CIF or charge Spanish VAT.
What you get when you buy is a confirmation email with a QR and, at best, a generic PDF receipt issued by the foreign entity — no Spanish VAT, none of the RD 1619/2012 fields. For a Spanish company, that document doesn't support a VAT deduction.
In cash terms: a €100 spend on an international platform costs you €100 net. The same spend invoiced correctly with 21% Spanish VAT costs you €82.64 (€100 - €17.36 recoverable VAT). Across a team's annual spend, the difference is material.
What an eSIM Teams invoice looks like
eSIM Teams operates under eSIM Ahora SL, a Spanish company registered with the Madrid Commercial Registry. A typical invoice for a Spanish client looks like this:
The bold fields are the ones your accountant or auditor checks to validate the invoice. eSIM Teams generates all of them automatically on every transaction — nothing to request separately.
EU B2B case: reverse-charge VAT
If your company is in the EU but outside Spain and has a valid intra-EU VAT ID (registered in VIES), invoices are issued without Spanish VAT. They include the line "Operation subject to reverse-charge — Art. 25 LIVA / Art. 196 Directive 2006/112/EC".
You then report the transaction as an intra-EU acquisition of services in your home country (Modelo 349 in Spain, DEB in France, equivalent forms in other member states). VAT is self-accounted on your local return — there's no VAT cash flow on the actual transaction.
We validate your VAT ID against VIES automatically at signup. If it's not valid in VIES at the time of the transaction, we default to charging 21% Spanish VAT, and you would need to reclaim it via the EU non-resident refund procedure (Modelo 360).
Non-EU case: clients outside the European Union
Services to businesses established outside the EU are not subject to Spanish VAT under the general place-of-supply rule for B2B services (Art. 69 LIVA). Invoices are issued without VAT, with the note "Operation not subject to Spanish VAT — Art. 69 LIVA". Your local tax obligations apply according to your jurisdiction.
Which other T&E expenses follow similar rules?
If your team travels for client visits, conferences, training, or remote work, mobile data is a fully deductible T&E expense when three conditions are met:
- 1.The invoice is in the company name, not the employee name.
- 2.The invoice meets the requirements of RD 1619/2012.
- 3.The expense is tied to a business activity (client visit, conference, team offsite, etc.).
International platforms typically fail on (1) and (2). A solution with a Spanish CIF like eSIM Teams resolves all three. The same logic applies to other T&E expenses: lodging, transport, client meals — all require a complete IVA invoice to be deductible.
Frequently asked questions
What if I'm an autónomo (sole trader), not a limited company?+
Same rules. Your invoice should go to your autónomo VAT ID (not your personal ID if they differ), and you can deduct VAT on your quarterly Modelo 303. eSIM Teams issues invoices to autónomos in the same format as to companies.
Can I deduct 100% of the VAT or only part?+
If the connectivity is used exclusively for business, 100%. For mixed personal/business use, you apply a reasonable allocation (typically 50% for general mobile, but it varies). For travel eSIMs clearly tied to work trips (client visits, conferences, offsites), 100% is defensible. Confirm with your accountant for your specific case.
How do I get the invoices to my accountant?+
From the eSIM Teams dashboard you download all monthly invoices as PDFs (or export CSV with tax base + VAT per line item). Invoices are also emailed to whatever billing address you configure.
Are invoices compatible with SII (Spain's real-time VAT reporting)?+
If your company is required to file SII (>€6M turnover), we deliver invoices in the compatible format. Most SMBs aren't on SII, and a standard PDF invoice is more than sufficient.
Can I request a pro-forma invoice before purchasing?+
For one-off transactions over €500 we can issue a pro-forma. Email partners@esimteams.com with your VAT ID and estimated volume.
Do you handle Modelo 349 (intra-EU operations reporting)?+
Yes. We file EU B2B operations on our quarterly Spanish Modelo 349. You also report the acquisition on your local equivalent — the tax authority cross-checks both sides.
In summary
For a Spanish company that runs eSIMs as a deductible expense, the difference between buying from an international platform and buying from a supplier with a Spanish CIF is 17.36% of the spend (recoverable VAT). For a 10-person team spending €1,000/month, that's €2,080 a year. If you're buying eSIMs as a business expense, demand a complete invoice with Spanish VAT. It's your right, and the difference shows up on the P&L.
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