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A company sought clarification on whether its electronic payment gateway activity, involving receiving funds from customers to transfer them to merchants after deducting a commission, was exempt from VAT. The DGT has ruled that this activity constitutes a collection service and, therefore, does not qualify for the exemption.
Cuestión planteada Exención de la operación del Impuesto sobre el Valor Añadido.
La actividad de gestionar pagos mediante un sistema electrónico, recibiendo ingresos para transferirlos posteriormente al cliente tras detraer una comisión, se considera gestión de cobro. Siguiendo la jurisprudencia del TJUE (sentencia AXA), estas operaciones financieras destinadas a obtener el pago de una deuda dineraria no están exentas. En consecuencia, el servicio prestado es una actividad sujeta y no exenta de IVA.
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