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A company has requested clarification on whether it must perform all operations listed in the law (extraction, manufacturing, transformation, storage, receipt, and dispatch) to be classified as a hydrocarbon factory. The Directorate-General for Taxes (DGT) responded that the core requirement is manufacturing, and that the other activities are complementary to facilitate operations.
This ruling clarifies the legal definition of a 'factory' for tax purposes, confirming that the primary activity of manufacturing is the determining factor, rather than the performance of every single activity listed in the legislation.
The tax team reviews your specific situation.
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