Doctrine by topic · DGT Observatory

Agency: DGT doctrinal evolution

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

← DGT Observatory

How the DGT's position has evolved

Settled doctrine High confidence 8 rulings · 2014–2022

Current position

Mediation or agency services performed on behalf of and for the account of another are subject to IVA (Value Added Tax). The place of supply is determined by the headquarters or permanent establishment of the business recipient. For an agency to create a permanent establishment, it must be authorized to contract on behalf of the taxable person or negotiate all elements of the contract by directing the process.

The DGT's position remains stable regarding the nature of mediation and its localization through general rules. The evolution focuses on the precision of the requirements for payments to act as 'suplidos' (disbursements on behalf of a client) and on the delimitation of when an agency generates a permanent establishment.

Turning points

  1. V1750-17

    Establishes the strict requirements for amounts paid by the agency to act as 'suplidos': express mandate, exact amount, and an invoice charged to the client.

  2. V0887-22

    Specifies that the agency only generates a permanent establishment if it is authorized to contract on behalf of the taxable person or directs the negotiation of all elements of the contract.

Analysis based on 8 of 8 rulings with a stated position. Updated 1 October 2026.

Rulings on this topic

8

Apply this to your case

VAT advisoryTalk to the team applying this doctrine daily.
Talk to the tax teamWe check whether this criterion affects you and what it means in your situation.
Email
Contact