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V2385-24 20 November 2024 · SG de Impuestos sobre el Consumo Criterion in force
IVA · arrendamiento de medios de transporte

Vehicle leasing and brokerage services subject to VAT according to place of supply rules

The taxpayer queried whether vehicle leasing and related brokerage services are subject to VAT in mainland Spain or the Canary Islands. The DGT ruled that taxability depends on whether the lease is short-term or long-term, and on the location of the recipient or where the vehicle is made available.

The question raised

Whether the services provided by the applicant are subject to Value Added Tax in the case of vehicles made available to its clients in the peninsula or in the Canary Islands, having acted as an intermediary in the operations through intermediary agencies, or having had clients book directly through the applicant's website.

The DGT's ruling

Short-term leasing is subject to VAT if the vehicle is made available in peninsular territory. In long-term leases, taxability depends on whether the recipient is a business or a final consumer and on their location. Intermediation services are subject to VAT if the recipient is a business established in the territory to which the tax applies or if the intermediation occurs in leasing operations carried out in said territory.

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