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V1645-20 27 May 2020 · SG de Impuestos sobre el Consumo Criterion in force
IVA · asesoramiento financiero

Comprehensive financial advisory services are subject to VAT and do not qualify as exempt mediation

An entity inquired whether its advisory and assistance services regarding investment or divestment operations of commercial companies could be considered financial mediation exempt from VAT. The DGT ruled that if provided as a comprehensive advisory service, they constitute a single supply subject to tax.

The question raised

Liability for Value Added Tax on the commissions charged by the consultant for advisory services.

The DGT's ruling

When analysis, valuation, and execution services form an inseparable set for the client, they constitute a single provision of financial advisory subject to VAT. For the financial mediation exemption to apply, the provider must be an independent third party that brings the parties together, and their work must go beyond the mere supply of information. If the client has already selected the investor or the objective, there is no mediation and the service is professional advisory subject to the tax.

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