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V3889-15 4 December 2015 · SG de Impuestos sobre el Consumo Criterion in force
IVA · exención

VAT exemption does not apply to investment management accounting services provided by a grouping to insurers

A branch of an insurance group has requested a ruling on whether a grouping established to centralise administration and investment accounting costs can benefit from the VAT exemption under Article 20.One.6º. The DGT ruled that these general services are not considered directly necessary for the insurance activity.

The question raised

The consulting entity raises the question of whether the services provided by said union, association, or autonomous entity to its constituent members could benefit from the exemption regulated in Article 20.One.6 of the Value Added Tax Act, as well as the possibility of its application despite services being provided to entities not established in the territory of application of the tax, as well as the deduction regime for said association.

The DGT's ruling

The exemption provided in Article 20.One.6 of the VAT Act does not apply to services of a general nature, such as accounting services related to investment management and the preparation of accounting and extra-accounting information, provided by an association to its member insurers. These services are not considered directly necessary for the provision of insurance services. The exemption is not intended to benefit the outsourcing of services or corporate restructuring, but rather to ensure balanced competition.

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