Skip to content
Back to index
V0991-25 11 June 2025 · SG de Tributos Locales Criterion in force
OTRO · impuesto sobre actividades económicas

Manufacture of cosmetics via outsourcing allows classification under production epigraph

A taxpayer asks whether the commercialisation of branded solid cosmetics, with production outsourced to a laboratory, should be taxed as trading or as manufacturing. The DGT states that material production outsourcing does not prevent classification as a manufacturing activity.

The question raised

It is asked whether, based on the activity described, the entity is correctly registered under the aforementioned heading 255.2, or if it should be registered under a trade heading.

The DGT's ruling

Manufacturing activity may be carried out through direct material execution or by entrusting the material execution to other entrepreneurs according to a prior design. Although subcontracting is not textually specified in the Tariffs, it must be classified under the heading of the first section corresponding to the manufacturing of that class of products. Registration in the manufacturing heading also authorizes wholesale, retail, and export.

Book your free first meeting