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V5456-26 ·7 August 2026 ·consulta-vinculante Medium impact
Tax

VAT on the supply of medicines is fully due upon making the goods available

A company has requested clarification on when VAT should be accrued for gene therapy medicines where payment is made in instalments based on specific milestones. The Directorate-General for Taxes (DGT) has determined that this constitutes a supply of goods rather than a continuous service operation; therefore, the tax becomes fully due at the time the product is delivered.

In 6 key points

How it affects those involved

This ruling clarifies that the supply of medicinal products, even when payment terms are structured around milestones, is treated as a single supply of goods for VAT purposes, requiring the full tax amount to be accounted for at the point of delivery.

Lifecycle

2026-08-07PublishedPublished 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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