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A company sought clarification on whether the consignment delivery of lubricants to its commercial agents constituted a transaction subject to VAT. The DGT ruled that it does, as the power of disposal over the goods is transferred.
Question raised: Taxation of consignment sales carried out by the applicant to commercial agents.
Consignment deliveries of lubricants to commercial agents are deliveries of goods because the right to resell the product in one's own name and at a stipulated price is transferred. The tax accrual occurs when the product is made available to the agent, regardless of whether payment is deferred. The taxable base is the total amount agreed upon between the parties. If agents return unsold products, the taxable base and the output tax must be rectified.
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