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V2086-23 17 July 2023 · SG de Impuestos Especiales y de Tributos sobre el Comercio Exterior y sobre el Medio Ambiente Criterion in force
OTRO · impuesto especial sobre envases de plástico no reutilizables

No liability for plastic packaging tax when no additional plastic is added during tray manufacturing

A manufacturer of plastic trays queried whether they are liable for the special tax on non-reusable plastic packaging when processing already taxed plastic coils. The DGT ruled that, as no additional plastic is incorporated, the manufacturing taxable event does not occur, and therefore the company is not a taxpayer.

The question raised

The taxpayer submits a series of questions regarding the special tax on non-reusable plastic packaging.

The DGT's ruling

Manufacturing does not include the production of packaging made exclusively from products subject to the tax or from other non-plastic products. As no additional plastic is incorporated beyond that of the purchased coils, the taxpayer does not perform the taxable event of manufacturing. Therefore, they are not a taxpayer, have no obligation to self-assess, nor to register in the territorial registry. However, they must state the amount of non-recycled plastic on the invoice if requested by their client.

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