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A cosmetics company has requested a ruling on whether the supply of products and management services (packaging, shipping, and collection) constitute independent operations or a single one. The DGT has determined that these services are ancillary to the principal supply and must be taxed as a single transaction.
Question raised In relation to the two alternatives proposed: taxable event, tax base, tax point, application of the equivalence surcharge. Whether the services invoiced by the applicant to the distributors constitute a transaction independent of the delivery of goods.
Delivery management services, such as packaging, transport, and collection management, do not constitute an end in themselves for the distributor, but are rather the means to enjoy the main service. Therefore, they are considered ancillary supplies to the delivery of goods and must be taxed as a single transaction under the regime for the delivery of goods. The tax point occurs upon the making available of the goods, and the tax base must include all expenses derived from the main and ancillary transactions.
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