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V2907-17 13 November 2017 · SG de Impuestos sobre el Consumo Criterion in force
IVA · prestación de servicios

Packaging services including materials may be considered a single supply of services if the material is ancillary

A company has requested clarification on whether packaging goods for a German client, including the cost of materials, should be treated as a single supply of services or as two separate transactions (a supply of goods and a supply of services). The DGT ruled that it depends on the customer's perception and whether the material is an end in itself or merely a means to provide the main service.

The question raised

Existence of a single transaction, packaging service, or of two transactions, delivery of material and packaging service.

The DGT's ruling

To determine whether there is a single transaction or several, the reality of the transactions must prevail from the recipient's perspective. If the client understands that they are purchasing two distinct benefits, there are two transactions; if the material is merely a means to enjoy the main service, it is considered a provision of services with an ancillary element. The fact of invoicing a single price is not decisive for this classification.

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