How the DGT's position has evolved
Current position
A bonded warehouse is an establishment authorized to receive, store, and distribute products with the tax accrued under reduced rates or exemptions. One cannot hold the status of a bonded warehouse if the activity consists of acquiring the product with the tax already accrued and charged. Excise Duty regulations do not regulate the figure of commercial intermediaries.
The DGT's position remains stable regarding the definition of the competencies and obligations of the bonded warehouse. Throughout the rulings, the need for specific authorizations for direct supply and the distinction between intermediation and effective supply has been clarified. No changes in criterion are observed, but rather a constant application of Excise Duty regulations.
Turning points
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Establishes that losses in storage and transport processes are considered justified if they do not exceed the prescribed regulatory percentages.
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Distinguishes between intermediation, which does not require authorization, and effective supply, which requires being a retailer or the holder of a bonded warehouse.
Analysis based on 22 of 24 rulings with a stated position. Updated 24 September 2026.