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A company has requested clarification on whether the transfer of land as security for a future sale of buildings constitutes a single VAT transaction. The Directorate General for Taxes (DGT) has ruled that the land transfer is an ancillary supply to the delivery of the buildings, forming a single economic transaction.
Question posed: Whether said operations constitute a single transaction for Value Added Tax purposes and, where applicable, the accrual thereof.
The delivery of the land and the future delivery of the buildings are two inseparable operations that form a single supply. The delivery of the completed buildings is the principal supply, while the transfer of the land as security is an ancillary supply. Accrual shall occur on the date on which the transfer effects of the building take place, without prejudice to accrual due to advance payments.
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