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V0898-26 ·23 April 2026 ·consulta-vinculante Medium impact
Tax

Manufacturing clinical trial batches with client-supplied active ingredient deemed a service provision

A Spanish lyophilization company asks whether manufacturing batches of product and placebo for a German client constitutes a delivery of goods or a service provision. The DGT determines that if the client-supplied active ingredient is not negligible, it constitutes a service provision exempt from Spanish VAT if the client has no permanent establishment in Spain.

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Lifecycle

2026-04-23PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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