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Customer Acquisition: 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 27 rulings · 2014–2023

Current position

The VAT exemption for insurance mediation requires that the service actively contributes to the approach between the insurer and the insured, through the search for customers or their connection with the entity. The mere supply of data or information regarding potential policyholders without additional actions that facilitate the conclusion of the contract is not considered mediation. The work must go beyond advertising or the simple supply of information.

The DGT's position remains constant in requiring an actual activity of approach between the parties. Throughout the rulings, it has been specified that the exemption does not apply to support services, mere advertising, or the supply of data without the capacity to influence the contracting. The doctrine has moved from a general definition to a strict delimitation of what does not constitute mediation.

Turning points

  1. V2848-17

    Establishes specific requirements for the exemption, requiring the provider to maintain a relationship with the insurer and participate in essential aspects such as the conclusion of contracts.

  2. V0480-19

    Defines that mediation must include elements such as advice, negotiation, or client filtering, excluding the mere clicking on advertisements or comparisons without the capacity to conclude the contract.

Analysis based on 25 of 27 rulings with a stated position. Updated 24 September 2026.

Rulings on this topic

24

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