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V1930-24 6 September 2024 · SG de Impuestos sobre el Consumo Criterion in force
IVA · entrega de bienes

VAT liability depends on vehicle location and the existence of a permanent establishment

A company in the Canary Islands has requested clarification on the VAT applicable to the sale of vehicles to a company in mainland Spain. The DGT indicates that if the vehicles are already located in mainland Spain, the transaction is subject to VAT, depending on whether the Canary Islands company has a permanent establishment or if the reverse charge mechanism applies.

The question raised

Question posed: Value Added Tax that must be settled as a consequence of the transaction.

The DGT's ruling

If the vehicles are located in mainland Spain and are made available to the customer there, the transaction is subject to VAT. If the Canarian company has a permanent establishment in mainland Spain, it shall be the taxable person and must charge 21%. If it does not have a permanent establishment, the Spanish acquiring company shall be the taxable person under the reverse charge mechanism. If the vehicles are sent from the Canary Islands to mainland Spain, an import will occur and the taxable person shall be the importer.

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