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V1943-22 12 September 2022 · SG de Impuestos sobre el Consumo Criterion in force
IVA · base imponible

Manufacturers may reduce VAT taxable base via credit notes for coupon reimbursements

A consulting entity inquired whether it could manage discount coupon campaigns for manufacturers and if the latter must issue credit notes. The DGT ruled that manufacturers may reduce their taxable base by the discount amount (excluding the VAT on the consumer sale) through a credit note, and that the consulting entity may issue such notes on behalf of the manufacturers provided legal requirements are met.

The question raised

Whether said discounts must be documented through the issuance of credit notes by the manufacturers. Possibility of the consulting entity issuing the corresponding credit notes on behalf of the manufacturers.

The DGT's ruling

The manufacturer may reduce the taxable base of its supplies to distributors by the amount of the discount reimbursed to end customers, excluding the VAT portion of the sale from the distributor to the consumer. This reduction must be documented with a credit note which does not require sending to the distributor, but must identify them. The discount amount is understood to include VAT and the manufacturer must prove the actual reimbursement. The consulting entity may issue these credit notes on behalf of the manufacturers if a prior agreement authorizing it exists.

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