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A state-owned commercial company has requested clarification on whether customs management services provided by its subsidiary are not subject to VAT. The Directorate-General for Taxes (DGT) has ruled that, as these activities are not on the list of exclusions, they are not subject to the tax if provided between entities that are entirely dependent on the same Administration.
Question raised Whether the services provided by the entity controlled by the applicant to the latter are not subject to Value Added Tax.
Los servicios de gestión aduanera y comunicaciones con autoridades no figuran en el listado de actividades sujetas del apartado F) del artículo 7.8º de la Ley 37/1992. Por tanto, están no sujetos al impuesto según el apartado E) del mismo precepto, al realizarse entre entidades íntegramente dependientes de la misma Administración Pública. No obstante, los servicios de transporte de bienes siempre estarán sujetos al IVA, independientemente del destinatario.
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