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V2845-18 26 October 2018 · SG de Impuestos sobre el Consumo Criterion in force
IVA · base imponible

Security deposits for reusable packaging are included in the VAT taxable base

A company renting reusable packaging has enquired whether security deposits are subject to VAT. The DGT has ruled that if the deposit is per individual item, it constitutes an ancillary supply subject to tax; however, if it is a global deposit, it is an exempt transaction that requires an invoice.

The question raised

1. Whether the rental and deposit operations are taxable operations and not exempt from Tax.

The DGT's ruling

The deposit for individual packaging constitutes an effective credit in favor of the lessor and is an accessory provision to the principal one, therefore it forms part of the VAT taxable base. In contrast, a global deposit is not accessory to the individual delivery and is considered a taxable but exempt operation. Exempt deposit provisions must be documented by invoice if carried out within the national territory.

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