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V1289-20 7 May 2020 · SG de Impuestos sobre el Consumo Criterion in force
IVA · entrega de bienes

Machinery installation and transport services are ancillary to the supply of goods

A company manufactures machinery and spare parts for export to other Member States, including assembly services. The DGT has ruled that installation and transport services are ancillary to the principal supply of goods.

The question raised

Whether deliveries including installation and assembly of equipment, which include transport and installation costs, as well as those of spare parts and components, are subject to, and where applicable, exempt from, Value Added Tax. Whether services for labor hours and associated costs provided by the applicant, where applicable, to the recipients and invoiced separately from the delivery of the machinery, are subject to the Tax.

The DGT's ruling

The delivery of machinery and its components is considered a delivery of goods when the entrepreneur provides the materials. Installation services, transport, and associated costs are ancillary supplies to the principal delivery and follow its tax regime. If the machinery is installed outside of Spain and involves immobilization, the delivery does not take place within the territory of application of the tax. Deliveries of goods to another Member State may be exempt if the requirements of intra-Community regulations are met.

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