Royal Law-Decree 14/2020 of 12 April, (published at the Official Gazette of the 15th of April) establishes an extension for the filing and payment of those returns with pending deadlines at the date of its publication, which will be extended until the 20th of May.
So, the new deadline for VAT returns (recapitulative returns could also benefit) corresponding to April or the first quarter of 2020 will be the said 20th of May. As an exception, for the case that the system adopted for the payment of the VAT return is its domiciliation at a Spanish bank account the new extended deadline will be the 15th of May.
However, this measure will only affect companies with a volume of transactions during the year 2019 under 600,000 Euros. When determining this figure, it must be remembered that according to the criteria of the Spanish General Tax Directorate:
- Exempt transactions, in any case, and transactions not subject to Spanish VAT when related to a Spanish permanent establishment will have to be taken into consideration.
- On the other side, intracommunity acquisitions and purchases eligible to reverse charge will have to be excluded. As resulting from the previous comment, supplies eligible to reverse charge (I.e. those made by non-residents companies without a PE in Spain) should also be excluded.
In any case, it should also be remembered that the extension of deadlines would only affect to those case where the tax management correspond to the central government. So, companies operating in the Canaries, where IGIC instead of VAT applies, or through a PE in the Vasque country or Navarre where special regulation applies should attend to the specific deadlines contemplated therein.