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A Spanish company provides taxi advertising services to a company established in Germany. The DGT has determined that, as no special rules apply and the recipient's registered office is outside Spain, the transaction is not located within Spanish territory.
Cuestión planteada Régimen del Impuesto sobre el Valor Añadido aplicable a dicha prestación de servicios.
Los servicios de publicidad no se consideran realizados en el territorio de aplicación del impuesto si el destinatario es un empresario con sede de su actividad económica fuera de España, sin establecimiento permanente ni domicilio en el territorio nacional. Al no aplicarse las reglas especiales de localización del artículo 70 de la Ley 37/1992, la prestación no está sujeta al IVA.
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