---
title: "Spain Intrastat threshold 2027: proposed rise to €800,000"
description: "Spain Intrastat threshold 2027: a draft order would double it from €400,000 to €800,000. Who must file, deadlines and why Amazon FBA stock transfers count."
image: https://www.axholdinggroup.com/hubfs/blog/spain-intrastat-threshold-2027.jpg
---

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[Blog](https://www.axholdinggroup.com/en/blog) · EU regulations

# Spain Intrastat threshold 2027: proposed rise to €800,000

19 October 2026 · Ax Holding Group™

![Spain Intrastat threshold 2027: proposed rise to €800,000](https://www.axholdinggroup.com/hubfs/blog/spain-intrastat-threshold-2027.jpg)

Quick answer

In 2026, you file Intrastat in Spain if your intra-EU dispatches or arrivals reach €400,000 a year in either flow. Spain's Ministry of Finance has published a draft order raising that threshold to €800,000 from the January 2027 reference period. It is still a draft and could change before it is approved.

If you sell on Amazon from Spain and move stock to warehouses in other EU countries, those movements count for Intrastat even when nothing has been sold. That is why the threshold matters to many sellers who have never thought of themselves as exporters. At the end of September 2026, Spain's Ministry of Finance put out for public consultation a draft order that doubles the exemption threshold. Here is what it says, who it affects and what you should check now.

## What changes with the Spanish Intrastat threshold in 2027?

The draft amends Article 5 of Order HFP/1480/2021, which sets the exemption thresholds for the Intrastat return. These are the figures:

| Flow | Current threshold | Proposed threshold |
| --- | --- | --- |
| Dispatches (goods leaving Spain for another Member State) | €400,000 a year | €800,000 a year |
| Arrivals (goods entering Spain from another Member State) | €400,000 a year | €800,000 a year |

According to the draft, the order would enter into force on 1 January 2027 and apply to returns whose reference period is January 2027 or later. Earlier periods stay under the rules in force at the time. The explanatory report says the €400,000 figure had not changed since 2015, and that the aim is to bring the thresholds into line with how intra-EU trade has grown and to cut the burden on businesses with smaller volumes.

The report also estimates the effect: on dispatches, filers would drop from about 21,000 businesses to about 15,000 (roughly 28% fewer), and on arrivals about 8,500 would no longer need to file (roughly 30%). Statistical coverage would fall to 96.2% in both flows, still above the 95% minimum set by Implementing Regulation (EU) 2020/1197.

## Who has to file Intrastat in Spain today?

Order HFP/1480/2021 sets three rules that the draft leaves unchanged:

- **Previous year:** you must file if the value of your dispatches or arrivals in the previous calendar year was not below the threshold.
- **Current year:** if you started the year exempt and your cumulative value reaches the threshold, you must file from the month you reach it. That first return covers only that month's movements.
- **Each flow separately:** dispatches and arrivals are assessed independently. You can be required to file one and not the other.

If you are required to file and have no movements in a month, you submit a nil return. The deadline is 12 calendar days after the end of the reference month, and returns are filed electronically through the Spanish Tax Agency's online portal.

## Why does this matter for Amazon FBA sellers?

Intrastat does not just track sales: it tracks the physical movement of goods between Member States. If you send your own stock from Spain to an Amazon fulfilment centre in France, Germany or Italy, or Amazon moves it for you through Pan-EU, those goods leave Spain without changing hands. The Spanish Tax Agency has a nature of transaction code for this: 3-1, "movements to or from a warehouse" (excluding call-off and consignment stock).

For VAT purposes, Article 9.3 of Spain's VAT Act (Law 37/1992) treats the transfer of your own business goods to another Member State as equivalent to an intra-Community supply, and the Tax Agency states that these transactions are reported on form 349. That is a separate obligation from Intrastat: form 349 is a tax return and Intrastat is a statistical one, and filing one does not replace the other.

In practice, a Pan-EU seller can pass €400,000 of dispatches without noticing, because what counts is the value of the stock leaving Spain for other warehouses, not your turnover in any one country. For a refresher on how the programme works, see our guide to [Pan-EU FBA requirements](https://www.axholdinggroup.com/en/blog/pan-eu-fba-netherlands-belgium?hsLang=en).

## What about Intrastat returns for 2026?

Nothing changes for 2026. Every Intrastat return with a reference period up to December 2026 stays under the €400,000 threshold. If you are required to file in 2026, keep filing every month, including December, which is due in January 2027.

For 2027, the previous-year rule would compare your 2026 movements with the threshold in force at that point. If the draft is approved as it stands, a seller with, say, €550,000 of dispatches in 2026 would no longer need to file for that flow in January 2027, unless they reach €800,000 cumulatively during the year. Until the order is published in Spain's Official State Gazette (BOE), don't stop filing.

## Checklist for sellers with stock in several countries

1. Add up your 2026 dispatches to date, including transfers of your own stock to Amazon warehouses outside Spain, not just sales.
2. Do the same for arrivals: goods coming into Spain from another EU country, including returns or removals of stock from warehouses in other countries.
3. Compare each flow separately with €400,000 (2026) and €800,000 (proposed for 2027).
4. Check that your transfers also appear on form 349, which is a separate tax obligation.
5. Ask your tax adviser to confirm your position. This article is for information only and is not professional advice.
6. Watch the BOE: the change only applies once the order is published. Read the final text before you stop filing.

## Frequently asked questions

### What is the Intrastat threshold in Spain in 2026?

It is €400,000 a year for each flow, dispatches and arrivals, under Article 5 of Order HFP/1480/2021. It applies to every Intrastat return with a reference period up to December 2026.

### Has the €800,000 threshold been approved?

No. As of 12 October 2026 it is a draft order that the Ministry of Finance has put out for public consultation. It will only apply once published in the BOE, and the final text may change.

### When would the new threshold apply?

According to the draft, the order would enter into force on 1 January 2027 and apply to returns whose reference period is January 2027 or later.

### Do stock transfers to Amazon warehouses count for Intrastat?

Yes. Intrastat records the physical movement of goods between Member States, even when ownership does not change. The Spanish Tax Agency classifies them under transaction code 3-1, movements to or from a warehouse.

### Are Intrastat and form 349 the same thing?

No. Intrastat is a statistical return with its own threshold. Form 349 is the recapitulative statement of intra-Community transactions for VAT, and transferring your own goods to another Member State is treated as equivalent to an intra-Community supply.

### What is the Intrastat filing deadline in Spain?

Twelve calendar days after the end of the reference month, filed electronically through the Spanish Tax Agency's portal. If you are required to file and have no movements that month, you submit a nil return.

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*Sources: [Draft order amending Order HFP/1480/2021 (Spanish Ministry of Finance)](https://www.hacienda.gob.es/sgt/normativadoctrina/proyectos/25092026-proyecto-om-modelo-1480-2021.pdf) · [Regulatory impact report for the draft](https://www.hacienda.gob.es/sgt/normativadoctrina/proyectos/25092026-main-proyecto-om-modelo-1480-2021-informacion-publica.pdf) · [Order HFP/1480/2021, consolidated text (BOE)](https://www.boe.es/eli/es/o/2021/12/28/hfp1480/con) · [Intrastat nature of transaction codes (Spanish Tax Agency)](https://sede.agenciatributaria.gob.es/Sede/aduanas/intrastat-obligaciones-estadisticas/noticias-interes/nuevos-codigos-naturaleza-transaccion-intrastat.html) · [Intra-Community acquisitions and supplies (Spanish Tax Agency)](https://sede.agenciatributaria.gob.es/Sede/iva/iva-operaciones-comercio-exterior/adquisiciones-entregas-intracomunitarias.html) · [Law 37/1992 on VAT (BOE)](https://www.boe.es/eli/es/l/1992/12/28/37). Information correct as of 12 October 2026.*

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