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V0256-25 5 March 2025 · SG de Impuestos sobre el Consumo Criterion in force
IVA · suplidos

Fees paid by a firm on behalf of a client may be treated as supplies if certain conditions are met

A firm asks whether advance payment of fees and taxes for vehicle transactions with a dealership's customers can be considered supplies. The DGT responds that such payments can only be treated as supplies if the conditions of mandate, payment on behalf of the customer, and exact justification are strictly met.

The question raised

Whether the expenses paid on behalf of the dealer's final client are considered disbursements.

The DGT's ruling

In order for the sums paid not to be included in the VAT taxable base, four conditions must be met: they must be paid on behalf of and for the account of the client (evidenced by an invoice charged to the client), be carried out under express mandate, be justified by the exact amount of the expense, and not allow the mediator to deduct the tax. If the management agency invoices the dealer, it must charge VAT for its services, but if it invoices the final client, it may exclude fees as disbursements if the requirements are met.

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