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V0508-22 14 March 2022 · SG de Impuestos sobre el Consumo Criterion in force
IVA · ejecución de obra

Supervision and design services are not classified as construction works for VAT purposes

A company requested clarification on when VAT should be accrued for site supervision and safety coordination services provided to Public Administrations. The DGT clarified that these services do not constitute construction works and are instead governed by the general rules for the provision of services.

The question raised

Question raised: The moment of accrual of Value Added Tax in the described services, whether when they are invoiced or when the actual collection occurs. Or, as in the case of services provided by the contractor to Public Administrations, at the moment of the receipt of the works.

The DGT's ruling

Project drafting, construction management, and health and safety coordination services are not considered works executions. The tax accrual occurs, as a general rule, when the operations are provided, executed, or carried out. If they are services of successive performance, accrual occurs when the portion of the price for each payment becomes due. Accrual shall only occur at the time of collection if advance payments exist.

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