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V2208-17 4 September 2017 · SG de Impuestos sobre el Consumo Criterion in force
IVA · sectores diferenciados

Invoicing for internal transfers is not mandatory if no separate business sectors exist

A company requested clarification on whether it must issue invoices for the transfer of goods between its wholesale and retail activities. The DGT ruled that, provided there are no separate business sectors, these transfers do not constitute transactions subject to VAT.

The question raised

Obligation to invoice the transfer of goods between the two activities of the taxpayer who only holds a single Tax Identification Number.

The DGT's ruling

The transfer of goods between activities does not constitute an operation subject to VAT if the taxable person does not maintain differentiated sectors. Differentiated sectors are considered to be those with distinct economic activities (according to the CNAE) or with deduction regimes that differ by more than 50 percentage points. If there are no differentiated sectors, internal transfers are not within the scope of the tax and do not require an invoice.

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