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V1308-23 17 May 2023 · SG de Impuestos sobre el Consumo Criterion in force
IVA · tipo impositivo

0% VAT rate applies to olive deliveries to cooperatives if sale or receipt occurs during the validity period

A farmers' association has enquired whether olive deliveries to cooperatives (whether held in deposit, on commission, or in fractional amounts) qualify for the 0% rate under Royal Decree-Law 20/2022. The Directorate-General for Taxes (DGT) has ruled that the applicable rate will depend on when the transaction is deemed to have accrued.

The question raised

Yes, for Value Added Tax purposes, the zero percent rate provided for in Royal Decree-Law 20/2022 shall apply to the following operations:

The DGT's ruling

The 0% rate applies to olives as they are natural products. In deliveries on deposit or commission, the rate shall be the one in force at the time of the sale by the cooperative to third parties. For fractional deliveries of the campaign, it shall apply if the reception period ends between January 1 and June 30, 2023. The 0% rate shall not apply to advance payments received before January 1, 2023.

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