How the DGT's position has evolved
Current position
The professional services of plastic artists aimed at the creation of original works are exempt from IVA (Value Added Tax). The deliveries of goods derived from these creations are taxed at the reduced rate of 10% if they meet the definition of works of art under article 136.Uno.2º of Law 37/1992. If they do not meet said requirements, the general rate of 21% applies. Restoration activities do not benefit from the exemption as they do not consist of an original artistic creation.
The DGT's position remains constant regarding the distinction between exempt services and taxable deliveries of goods. It has been specified that the exemption is limited to original creation, excluding restoration (V1032-21), and clarifying that the medium or means of delivery (electronic) does not alter the nature of the operation (V0025-21).
Turning points
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Clarifies that the restoration of works is not exempt because its object is not an original artistic creation.
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Establishes that the sending of illustrations by electronic means does not convert the activity into a service provided by electronic means.
Analysis based on 19 of 19 rulings with a stated position. Updated 25 September 2026.