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V0987-22 5 May 2022 · SG de Impuestos sobre el Consumo Criterion in force
IVA · arrendamiento con opción de compra

Taxable base for leasing purchase options is the cost of the asset and the option, excluding financial charges

The inquiry seeks clarification on how to determine the VAT taxable base when a purchase option is exercised in a leasing contract, particularly under the special regime for groups of entities. The DGT rules that exercising the option constitutes a supply of goods and details how to calculate the base according to the applicable regime.

The question raised

1. Taxable base in Value Added Tax in the event of the exercise of the call option in a leasing contract.

The DGT's ruling

The exercise of the call option is considered a supply of goods, and the tax shall accrue at that moment. If the advanced modality of the special regime for groups of entities is applied, the taxable base shall be the total amount of the consideration (cost of the good and the call option), excluding the financial charge for deferred payment. If the option is exercised before entering said regime, the base shall be quantified by the costs of the good upon which the tax has been borne, taking into account the previous use of the good.

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