Doctrine by topic · DGT Observatory

Customs Agent: 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 12 rulings · 2015–2022

Current position

Transport services related to exports are exempt from IVA (Value Added Tax) when the recipient is the exporter, the purchaser, or intermediaries (freight forwarders, consignees, or customs agents) acting on behalf of the exporter or the purchaser. The exemption does not apply if the intermediary acts in its own name or if it acts in its own name on behalf of another intermediary who also acts in its own name.

The DGT's position remains constant regarding the application of the IVA exemption on transport services for export. Consultations repeatedly confirm that the exemption depends on the customs agent or intermediary acting on behalf of the exporter or purchaser and not in its own name.

Turning points

  1. V1188-16

    The repeal of the provision that allowed the reimbursement of IVA on imports through customs agents acting in their own name and on behalf of importers is established.

Analysis based on 12 of 12 rulings with a stated position. Updated 27 September 2026.

Rulings on this topic

12
V1188-16 23 Mar 2016

VAT refunds on imports via customs agents abolished

SG de Impuestos sobre el Consumo
reembolso del impuestoagente de aduanasimportación de bienesderecho a la deduccióncuotas satisfechas LIVA — Ley 37/1992 del IVA art. 87.2.3LIVA — Ley 37/1992 del IVA art. 87.3
Affects CompanyExpat · Non-residentIndividual

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