As there is not a special reference in the commented article to non-resident companies operating in Spain, its provisions would be fully applicable to them. However, based in the Spanish VAT and invoicing regulations:
a) A pre-requisite for a non-resident company to be subject to any invoicing requirement in Spain is that it is obliged to apply the Spanish regulations for invoicing.
b) This would normally be the case when, regardless of its being established or not in the Spanish VAT territory, the non-resident company is the appointed taxable person for the Spanish VAT accrued in the transaction.
This implies both that the transaction is located in the Spanish VAT territory and that no internal reverse charge rule applies, whereby the position of taxable subject shifts from the supplier to the client.
Source: ivaconsulta.com
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