If nothing has actually changed hands, that payment doesn't need an invoice
You'll learn to tell money that comes in from a sale apart from money that just passes through your account without actually being a sale, and how to record it without issuing a single extra invoice.
By Yodai · Published September 6, 2026 · Updated October 12, 2026
A payment lands in your account and you're not sure what to do with it. It might be the deposit on a rental you're about to return next week. It might be the $2 charge you made yourself to test that your payment gateway works. It might be a duplicate charge: you charged a client $45 twice for the same service because the connection dropped mid-payment.
When you charge for a sale, the usual question is which document to give the customer: a full invoice or a simplified receipt (what the regulation calls a simplified invoice), depending on who's buying and how much. But here the question comes first: is this actually a sale? If it isn't, no invoice or simplified receipt applies, because there's no sale to document: the Invoicing Regulation requires an invoice for the delivery of goods and the provision of services, and here there's neither.
Three charges that aren't a sale
A security deposit doesn't pay for anything: it's a guarantee that goes back to its owner if everything goes well. If you rent out photography gear and ask for a $150 security deposit, that money isn't yours while the gear is out. What's yours is the rental price, not the security deposit.
Don't confuse this with a deposit: a deposit is part of the price paid to you upfront, it's yours to keep, and it does need its own document. The VAT Law says that for advance payments, the tax is due "at the time of full or partial collection of the price, for the amounts actually received," and the Invoicing Regulation also requires an invoice for payments received before the sale happens. A security deposit isn't the price of anything, which is why it doesn't need one. That said, if it ends up being used as payment, it stops being a security deposit: the Directorate General of Taxes says that when funds held as a security deposit are applied toward payment, that money becomes payment for a transaction subject to VAT.
A test charge isn't a sale either: it's a charge you create yourself to check that your payment processor is working, and you cancel or refund it right away. There's no customer on the other end, and nothing has been delivered. Even better if no real money moves: in Stripe's test environment, for example, transactions are simulated with test cards and "don't move funds," and its terms of service prohibit testing in live mode with real payment data.
A duplicate charge is the riskiest of the three because it looks like a sale: the name, amount, and date match a real service. But only one of the two charges corresponds to something delivered. The second is a mistake to undo, not a second sale: the Civil Code says that anyone who receives something they had no right to collect, delivered by mistake, has an obligation to return it.
- A product, a service, or the right to use them changed hands
- The money stays with you if everything goes as planned
- A full invoice or a simplified receipt applies, depending on who's buying
- The money goes back to its owner as soon as a condition is met or you catch the error
- No product or service was delivered in exchange
- No tax document applies, though it's still worth keeping a record
Which one applies: If the money can be returned without you having delivered anything in exchange, don't invoice it. Only issue an invoice or receipt when the charge is payment for something you've already given or are about to give.
When part of the deposit stays with you
If the equipment comes back broken and you deduct $40 from the security deposit to cover the repair, that $40 stays with you, but it doesn't turn into a sale: it's compensation for the damage. The VAT Law excludes from the tax base any compensation that, by its nature, isn't payment for a sale or a service. And the Directorate General of Taxes applies this to security deposits: a rental deposit that covers damage, or the deposit charged when lending out glassware in case it doesn't come back, has a "compensatory nature" and isn't subject to VAT. The rest, the $110 you return, is still a security deposit.
The paperwork worth keeping
Not needing an invoice doesn't mean you skip leaving a trail. If someone asks about their deposit six months from now, you want something in writing that says how much it was, why you collected it, and when it gets returned. The same goes for a duplicate charge: your client needs to see in writing that the second charge has been voided, even if that paper isn't an invoice.
That document is called a receipt or proof of payment, and it doesn't show separate VAT or an invoice number. In the glassware ruling, the Directorate General of Taxes notes that if there's no transaction for VAT purposes, there's no obligation to issue an invoice, "without prejudice to issuing any other type of document to substantiate" the charge for other purposes. The date, amount, description, and refund terms are enough. If you keep part of it, note how much and why.
The mistake that costs you
With that settled, next up is putting a number on what actually is a sale.
- You can tell a charge that's a sale apart from one that just moves money without being one
- You leave a simple receipt for the deposit and the duplicate charge, with no invoice number
- You know that the part of a security deposit you keep for damage is compensation: it doesn't need VAT or an invoice, but you should still put it in writing
- You cancel any duplicate charge the same day, before it mixes in with the rest of the month's charges
Sources
- Royal Decree 1619/2012, of November 30, approving the Regulation governing invoicing obligations, articles 2, 4, and 15. Official State Gazette (BOE), consolidated text (last update published March 31, 2026).
- Law 37/1992, of December 28, on Value Added Tax, articles 75, 78, and 89. Official State Gazette (BOE), consolidated text (last update published October 7, 2026).
- Binding Ruling V2178-22, of October 17, 2022. Directorate General of Taxes, Ministry of Finance, 2022.
- Binding Ruling V2169-25, of November 13, 2025. Directorate General of Taxes, Ministry of Finance, 2025.
- Royal Decree of July 24, 1889, publishing the Civil Code, article 1895. Official State Gazette (BOE), consolidated text (last update published January 3, 2025).
- Testing. Stripe Documentation, accessed October 2026.