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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.
Cuestión planteada Existencia de una operación única, servicio de embalaje, o de dos operaciones, entrega de material y servicio de embalaje.
Para determinar si existe una operación única o varias, debe prevalecer la realidad de las operaciones desde la perspectiva del destinatario. Si el cliente entiende que compra dos prestaciones distintas, existen dos operaciones; si el material es solo un medio para disfrutar del servicio principal, se considera una prestación de servicios con un elemento accesorio. El hecho de facturar un precio único no es determinante para esta calificación.
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