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A company supplies fuel to ships at Spanish ports, invoicing an entity in Ireland. The DGT determines that deliveries are subject to VAT because the due date of special taxes occurs at the point of departure from the fiscal depot.
Cuestión planteada Si las entregas de bienes efectuadas por la consultante a favor de la matriz irlandesa están exentas del Impuesto sobre el Valor Añadido en virtud de lo dispuesto en el artículo 21 o en virtud del artículo 23 de la Ley del impuesto entendiendo que dichas entregas se efectúen durante la vigencia del régimen de depósito distinto del aduanero.
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