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V2039-20 19 June 2020 · SG de Impuestos sobre el Consumo Criterion in force
IVA · instituciones de inversión colectiva

Marketing services for UCITS provided by delegated agents are exempt from VAT

A collective investment scheme management company has enquired whether VAT exemption remains applicable when the marketing function is delegated to agents. The Directorate-General for Taxes (DGT) has ruled that this activity is exempt as it constitutes a specific and essential function of management.

The question raised

Whether the intermediation services provided by agents are exempt from Value Added Tax

The DGT's ruling

The marketing of units in collective investment schemes carried out by agents, by delegation from the management company, is exempt from VAT. This function is considered part of a distinct set of activities essential for the management of such institutions. The exemption applies regardless of whether the management company subsequently provides other services to the unit holders that are not exempt.

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