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V0199-20 ·29 January 2020 ·consulta-vinculante Medium impact
Tax

Form 548 filing not required if manufacturer retains ownership of products until sale

A white-label alcoholic beverage manufacturer inquired whether they must submit Form 548 regarding duties passed on to the distributor. The Directorate-General for Taxes (DGT) ruled that, as the manufacturer remains the owner of the products until the point of sale, the duty pass-on is direct, and they are not required to submit this informative declaration.

In 6 key points

How it affects those involved

This ruling clarifies the reporting obligations for manufacturers under the suspensive regime, specifically regarding the ownership of goods and the necessity of Form 548 when duties are passed on directly.

Lifecycle

2020-01-29PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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