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Financial Advisory: 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 13 rulings · 2015–2023

Current position

Financial advisory is subject to IVA (Value Added Tax) at the general rate of 21% when carried out in the course of a business or professional activity. The exemption for financial mediation only applies if the provider is an independent third party who brings the parties together and actively participates in the negotiation. If the work is limited to evaluating investments, designing plans, or performing analyses, it is classified as advisory services and is subject to the tax.

The DGT's position remains constant regarding the distinction between exempt mediation and taxable advisory services. The interpretation has been reinforced that services of analysis, valuation, and execution form a single provision of financial advisory subject to IVA when they are interrelated. No change in criterion is observed, but rather a consolidation of the requirement for active mediation work to qualify for the exemption.

Turning points

  1. V3319-17

    Establishes that strategy design, analysis, and execution form a single provision of financial advisory subject to IVA when they are interrelated in a global contract.

  2. V3135-20

    Specifies that activities such as evaluating investments, designing economic plans, or performing due diligence constitute advisory services subject to IVA and not exempt mediation.

Analysis based on 13 of 13 rulings with a stated position. Updated 27 September 2026.

Rulings on this topic

13
V2186-23 26 Jul 2023

Financial advice provided by an individual is subject to 21% VAT

SG de Impuestos sobre el Consumo
actividad empresarial o profesionalordenación de mediossujeción al impuestoexención por servicios formativosasesoramiento financiero LIVA — Ley 37/1992 del IVA art. 4.1LIVA — Ley 37/1992 del IVA art. 5.1
Affects CompanyExpat · Non-residentIndividual
V2100-18 16 Jul 2018

Financial advisory services to non-EU individuals are not subject to VAT

SG de Impuestos sobre el Consumo
asesoramiento financierogestión de patrimonioslocalización de serviciosno sujecióndestinatario no empresario LIVA — Ley 37/1992 del IVA art. 69.UnoLIVA — Ley 37/1992 del IVA art. 69.Dos
Affects CompanyExpat · Non-residentIndividual

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