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V2581-23 26 September 2023 · SG de Impuestos sobre el Consumo Criterion in force
IVA · mediación financiera

Mortgage comparison platform services subject to VAT as they do not constitute mediation

An entity sought clarification on whether its technological platform for bespoke mortgage offers constituted VAT-exempt financial mediation. The DGT has ruled that, as the service is limited to providing a comparison tool without offering advice or intervening in the conclusion of the contract, it is subject to VAT.

The question raised

Whether the service provided by the platform can be considered a financial mediation subject to and exempt from Value Added Tax.

The DGT's ruling

For exempt mediation to exist, the provider must be an independent third party performing functions that go beyond the mere supply of information, providing an active element that facilitates contracting. The mere comparison of products or the supply of information without advice or the capacity to conclude the contract does not constitute mediation. In this case, the platform only offers a panel of offers where the user decides freely, without the entity providing advice or advancing the formalization of the contract.

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