VAT on Booking and Airbnb commissions: the platform charges it, you do not deduct it, and you do subtract it on your tax return

Short answer: since 1 January 2023 the Booking or Airbnb commission reaches you with 21 % VAT on the invoice, and the one who declares it in Spain is the platform, not you. The VAT Act expressly excluded intermediation services in property rentals from the "reverse charge" (art. 84.One.2.a, letter e'), so you do not have to file form 309, register in the ROI (VIES) or file form 349 for those commissions. That VAT cannot be deducted, because your rental is exempt, but you do subtract it on your income tax return as part of the commission expense. For a flat paying €3,500 in commissions a year, that is about €735 of VAT that forms part of the cost.

Why do so many people say the opposite?

Because until 2022 it was the other way round. Booking (Netherlands) and Airbnb (Ireland) invoiced without VAT and the owner, as a "business" for VAT purposes, had to self-assess 21 % on form 309, register in the ROI and file form 349. Many guides, and some advisers, still describe that scheme. Law 31/2022 (the 2023 budget) changed article 84 of the VAT Act and since then the taxable person is the platform. If your accountant still makes you file form 309 for platform commissions, show them the article.

So what do I have to do?

1. Look at the platform's invoice: it must show the base (the commission), the VAT at 21 % and the total. Airbnb breaks it down that way on the service fee invoice; Booking, on the commission invoice.
2. Keep it: the base and the VAT are a deductible expense on your IRPF, in proportion to the rented days like everything else (Deductible expenses).
3. Nothing else. If you only rent and have no other VAT activity, you file neither form 303, nor 390, nor 309, nor 349 for this.

If an invoice arrives without VAT, do not take it as correct: ask the platform or your accountant. With the law in hand, the obligation to charge VAT is the platform's, not yours.

Can I deduct that VAT?

No. Tourist rental without hospitality services is exempt from VAT (Is there VAT on holiday rentals?), and anyone who only carries out exempt transactions does not deduct the VAT they bear. It is pure cost, like the VAT on the manager's or the cleaner's invoice. What you do is subtract it on your income tax return, within the expense.

How much is it in a normal year?

That is why, when you compare platforms or calculate profitability, Airbnb's real commission is not 15.5 % but 18.8 %, and Booking's is not 15 % (plus 1.3 % for payment handling) but close to 19.7 %. The calculator already takes it into account.

And the manager's invoice?

The same: the manager is Spanish, invoices you with 21 % VAT, you do not deduct it and you subtract it on your income tax return as an expense. A manager who invoices you "without VAT" or does not invoice at all is a warning sign: see Signs of a bad manager.

And if the listings are in the manager's name?

Then the platform's commission (with its VAT) is invoiced by Booking or Airbnb to the manager, and the manager pays you the net. It is one of the reasons why some owners prefer the listings to be in the manager's name, and others prefer to keep them in their own name to keep reviews and control. The two options are compared in Who is the holder of the listing?.

What do we do?

We give each owner an annual summary with each platform's commissions and their VAT, per home, so their accountant can enter it on the tax return in two minutes. And if an adviser asks them for form 309 for Booking or Airbnb commissions, we send them this guide with the article.