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V3017-20 6 October 2020 · SG de Impuestos sobre el Consumo Criterion in force
IVA · inversión del sujeto pasivo

Exemption from collection management fees depends on whether the service performs essential functions or is merely administrative

A taxpayer has enquired whether the fees paid to electronic money platforms for managing card collections are exempt from VAT. The DGT indicates that if the service only performs technical or administrative data exchange tasks without assuming the essential functions of fund transfers, the exemption does not apply.

The question raised

Liability and, where applicable, exemption of the commissions paid by the consultant for the management of their collections regarding Value Added Tax.

The DGT's ruling

The location of services is determined by the recipient's headquarters, applying the reverse charge mechanism. For payment management to be exempt, the service must fulfill the specific and essential functions of the financial transaction, altering the legal and material position of the parties. If the provider only performs support tasks, such as obtaining and transmitting data or managing settlement files, the service is subject to VAT.

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