Black Friday and Tax Office: tax obligations that businesses must meet during the discount campaign

 

Black Friday has become one of the biggest sales peaks of the year, both for physical stores and e-commerce platforms. However, this increase in operations also increases the risk of making tax errors: miscalculated taxable bases, unjustified discounts, unrevised invoices, or incorrect entries in the VAT record books.

Although from a commercial point of view a discount may seem simple, from a tax perspective it can modify the taxable base of the tax, require the issuance of corrective invoices, and demand proper accounting registration. In this article, we analyze, in a practical way, what the regulations require during intensive promotion campaigns like Black Friday.

1. How Black Friday discounts affect the taxable base of VAT

VAT must be calculated on the amount actually paid by the customer. However, the regulations distinguish between two types of discounts.

Discounts applied at the time of sale

These are the most common during Black Friday, either at the cash register or at the online store's checkout.

Article 78, 3 of the VAT Law establishes that the taxable base will not include discounts granted prior to or simultaneously with the transaction, provided they are duly justified.

Example:

• Initial price: €100

• Black Friday discount: 20%

• Final taxable base: €80

VAT is calculated on the reduced base of €80, not on the original €100.

Post-sale discounts

These include rebates, commercial returns, or other discounts applied after the transaction.

According to Article 80, 1 of the VAT Law, the taxable base can be reduced when the discount is granted subsequently and is justified. For this, a corrective invoice must be issued, as required by Article 24, 1 of the VAT Regulation. Without this invoice, the declared taxable base cannot be modified.

2. Invoicing obligations during the campaign

The way to correctly invoice a discount depends on when it is granted.

A) Discount applied in the sale

The invoice must reflect:

• The unit price without taxes

• The applied discount (if not included in the unit price)

• The resulting taxable base

The discount must be shown on the original invoice.

B) Post-sale discount

A corrective invoice must be issued, meeting all the formal requirements established by the regulations. It is essential both to modify the issuer's taxable base and for the recipient to adjust their deductible VAT.

3. How Black Friday sales should be recorded

Retailers are obliged to correctly reflect these transactions in their VAT record books.

Record book of issued invoices

According to article 63 of the VAT Regulation:

• The taxable base must be recorded according to the amount actually due, after applying justified discounts.

• Any corrective invoice must be recorded separately, identifying the rectified amount and the reason for the rectification.

Proper maintenance of these records is essential to justify the transactions to the Tax Authorities.

4. Tax checklist for retailers during Black Friday

Before starting the campaign, retailers should review:

• If the discount is applied in the sale or afterwards

• If the recorded taxable base matches the price actually paid

• If the invoicing system correctly reflects the discounts

• If rectifications can be issued without incidents

• If the e-commerce recalculates the VAT after applying discounts

• If pricing automatisms are up to date

A common mistake is for the website to display the discounted price but the system continues to calculate the VAT on the original base, generating discrepancies easily detectable by the Tax Agency.

Intensive discount campaigns imply commercial opportunities, but also require precise handling of tax obligations. Inadequate documentation, incorrect calculation of the taxable base, or incomplete accounting records can result in sanctions, requirements, and costly adjustments.