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I am at the Vacation Rental World Summit in Lyon, and Spain changed the rules overnight.
Its lower house threw out the 10% VAT charge on short lets on Friday 2 October. It was republished yesterday and came into force this morning.
Royal decree law 29/2026 is in official state gazette 249, promulgated Tuesday 6 October. I pulled both decrees and diffed the operative paragraph. The short let wording is identical to the text the chamber killed 6 days ago, and it still takes effect on 1 December 2026.
First, the mechanism. The hotel services test is old law and has been in the VAT act for years. What this decree adds is a second, alternative trigger: the exemption goes where the duration in favour of one and the same tenant does not exceed 30 nights. The decree says either of the 2 circumstances is enough, so the services limb and the 30 night limb each work on their own. The carve-out for a property in which the landlord has his habitual residence sits inside the 30 night limb.
Second, something in this decree was not in the one that was repealed. A new article 20 requires a letting advertisement to carry the unit's identifying number, code or title, where applicable. The preamble names the municipal and regional codes for tourist use dwellings as its example. The 2024 rentals registry decree is why that matters. The state's own consolidated text of it records that the Supreme Court annulled the single registration procedure and the registration number references, in judgments of 19 May, 21 May and 1 June 2026. The duty is being rebuilt at statutory rank. That limb started this morning, not in December, it carries no penalty inside this decree, and the decree assigns a constitutional competence title to every article except that one.
Third, the arithmetic. Both chambers were dissolved on Tuesday and the election is Sunday 29 November. The confirmation vote goes to the lower house's standing deputation under article 78 of the Constitution, inside 30 days of promulgation, which lands in the first week of November. 54 days to the tax date. Under 30 to the vote.
What I would do this week. Stop modelling it as 10 points off margin, because a taxable supply unlocks input VAT on cleaning, linen and commission. Then look at payment terms, because the tax accrues when the price falls due and on deposits when you take them.
A repealed tax is not a dead tax while the government still holds the pen. It holds it until polling day, 2 days before this one bites.
If you are in Lyon, come and tell me how you are pricing December.