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Cooperative Activity: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 8 rulings · 2014–2026

Current position

The provision of services by an agricultural cooperative to its members derives from its cooperative activity and is taxed at the reduced rate of 10% if they fulfill its corporate purpose. The 10% rate also applies to services necessary for the development of an agricultural, forestry, or livestock holding provided to its owner. The reduced rate does not apply to charges for collaboration in structural expenses or to the transfer of use or enjoyment of assets.

The DGT's position remains stable regarding the application of the 10% reduced rate for cooperative activity. Throughout the rulings, it has been specified that the provisions must be expressly listed in the law and be necessary for the holding. The distinction between services derived from cooperative activity and other concepts, such as collaboration in structural expenses, has been maintained.

Turning points

  1. V0812-21

    Specifies that charges for collaboration in structural expenses are not considered services of the cooperative activity and are taxed at 21%.

  2. V1581-21

    Establishes that for the reduced rate, the provisions must be expressly listed and cannot be transfers of use or enjoyment of assets.

Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8

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