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A company inquired whether it could blend aromatised wines (22% vol.) with still wine to reduce the alcohol content to 15.2% vol. at a warehouse. The DGT ruled that this transformation process must be carried out within a manufacturing facility under a suspensive regime.
Question posed: Possibility of reducing the alcohol content of received products to 15.2% vol in the warehouse through the addition of still wine, under the protection of Article 15.3 of the Excise Duties Law.
The mixing of an intermediate product with a still wine constitutes a transformation operation. Pursuant to Article 15.3 of Law 38/1992, to carry out this transformation outside of a factory, the sum of the tax amounts of the initial products must not be less than that of the final product. In this case, the tax amount of the resulting intermediate product is higher than the sum of the tax amounts of the mixed products, therefore the operation must be carried out in a factory.
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