VAT Rules for Amazon Vine Reviewers in Spain

The Spanish Tax Authority issued a consultation paper explaining how VAT rules apply to Amazon Vine, an invitation-only program that invites select customers who regularly write reviews. The main reason for the Tax Authorities' explanation of the applicable rules is that participants in this program are eligible to request free products offered through the Amazon Vine program, either by Amazon itself or by its selling partners.

VAT Rules for Amazon Vine Members

In its paper, the Tax Authority recalled that, under Spanish VAT law, VAT applies to supplies of goods and services carried out for consideration by individuals or businesses that organize material or human resources on their own account to intervene in the production or distribution of goods or services, even on an occasional basis. 

From that perspective, the Tax Authority noted that any individual who publishes reviews in exchange for goods is carrying out a taxable supply of services, regardless of how frequently the activity occurs. In contrast, only truly one-off and isolated actions without continuity would fall outside this classification.

Consequently, when reviews are provided in exchange for goods, as with Amazon Vine, the reviewer is treated as a taxable person and must charge VAT on the value of the services if they are supplied in Spain. The Tax Authority added that this constitutes a barter of services for goods, or a barter transaction.

The taxable base for non-monetary consideration in these cases, such as products, is the monetary value agreed between the parties, which generally corresponds to the value of the goods received. Therefore, the reviewer must charge VAT on the services using that value as the taxable base and may, in turn, deduct the input VAT borne on the goods received, provided all legal requirements are met, including possession of the proper invoice.

Conclusion

Based on the Tax Authority's clarification, one thing is sure: free does not mean tax-free. Individuals who receive products through Amazon Vine in exchange for their reviews are no longer just helpful customers. Under VAT law, they are operating as a taxable person. Thus, what may seem like a membership in an exclusive club for trusted reviewers can, from a VAT perspective, quietly turn hobbyists into taxable service providers overnight. 

Source: Spanish Tax Authority - Consultation V2159-25