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V4954-16 15 November 2016 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · intermediación

Intermediation and payment management fees subject to CIT and VAT based on service location

A company acting as an intermediary in online purchases has requested clarification on the taxation of its income. The DGT has determined that only commissions constitute income for Corporate Income Tax purposes, whereas for VAT, commissions are subject to the tax according to the rules governing the location of services.

The question raised

Consequences of this method of operation for Corporate Income Tax and Value Added Tax purposes.

The DGT's ruling

In Corporate Income Tax, commissions for brokerage services, payment management, and advisory services form part of the taxable base, but the purchase and sale amount is not income as it is a disbursement. In VAT, the commission is subject to tax when the service is deemed to be performed in Spanish territory, applying the rules of localization for mediation services rendered on behalf of and for the account of others.

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