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A company sought clarification on whether granting a franchise system alongside the delivery of necessary machinery constituted a single transaction or multiple ones. The DGT determined that these are two separate operations: a service provision for the assignment of rights and a supply of goods for the equipment.
Cuestión planteada Deducibilidad del Impuesto soportado.
La concesión de un derecho de explotación mediante franquicia es una prestación de servicios. La entrega de materiales, mobiliario y máquinas constituye una operación de entrega de bienes independiente, ya que no es un medio para disfrutar del servicio principal, sino un fin en sí mismo. Por tanto, deben apreciarse por separado y no como una prestación única.
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