How the DGT's position has evolved
Current position
The nature of a voucher as univalent or polyvalent is determined at the time of its issuance according to its design and conditions of use. A voucher is polyvalent if its redemption can lead to services within or outside the territory subject to VAT (IVA), or with different tax rates. In polyvalent vouchers, the transfer does not constitute the delivery of the underlying service, but rather a distribution or promotion service with a margin-based tax base.
The DGT has maintained a constant position regarding the distinction between univalent and polyvalent vouchers. The criterion is based on the capacity of the redemption to generate different locations or tax rates. No change in doctrine is observed, but rather a systematic application of the criteria of Directive 2016/1065 to define the nature of the voucher.
Turning points
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Establishes that the nature of the voucher is determined by the design and conditions of use at issuance, and not by the certainty of the end user.
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Defines that if vouchers can potentially be used throughout the entire Spanish territory, including the Canary Islands, Ceuta, and Melilla, they are considered polyvalent vouchers.
Analysis based on 10 of 11 rulings with a stated position. Updated 28 September 2026.