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V1542-18 6 June 2018 · SG de Impuestos sobre el Consumo Criterion in force
IVA · mediación

Financial intermediation by dealerships may be VAT exempt if mediation requirements are met

A vehicle dealership has requested clarification on whether its financial intermediation activities are exempt from VAT and how discounts from manufacturers and entities affect the taxable base. The DGT has ruled that mediation is exempt provided the dealership acts as an independent third party bringing the parties together, and has analysed the treatment of discounts and commissions.

The question raised

1. Whether the exemption provided for in Article 20.One paragraphs 18.m) of Law 37/1992 is applicable to financial intermediation activity.

The DGT's ruling

Financial intermediation activity is an VAT-exempt mediation if the provider is a third party distinct from the buyer and the seller, and their functions extend beyond the mere provision of information. It is considered that the dealer operates two differentiated sectors: vehicle sales and financial mediation. Discounts granted by manufacturers to promote sales allow for a reduction in their taxable base, but do not affect the taxable base of the dealer's sale to the customer if the manufacturer assumes the discount directly.

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