Doctrine by topic · DGT Observatory

Author: 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 · 2014–2021

Current position

The exemption under Article 20.One.26º of Law 37/1992 is limited exclusively to the professional activities of authors as natural persons. Services provided by commercial entities or companies do not benefit from this exemption. Likewise, the assignment of exploitation rights is classified as income from employment, unless the author organizes their own means of production or human resources on their own account.

The DGT's position remains constant in delimiting the exemption, always restricting it to the natural person who is the author. No changes are observed in the interpretation of the nature of creation services or the delivery of works of art. The doctrine is consistent in excluding legal entities from the benefits reserved for the professional activity of the author.

Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8
V1617-19 28 Jun 2019

Author services provided to news agencies are subject to VAT

SG de Impuestos sobre el Consumo
exenciónderechos de autorprestación de serviciosautorentidad mercantil LIVA — Ley 37/1992 del IVA art. 4LIVA — Ley 37/1992 del IVA art. 11
Affects CompanyExpat · Non-residentIndividual

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