How the DGT's position has evolved
Current position
The liability for IVA (Value Added Tax) of services provided by a partner depends on the existence of independence or labor subordination. This is determined through the analysis of the organization of own means (human and material), the assumption of economic risk, and responsibility towards third parties. If the partner is subject to the organizational criteria of the company and does not receive remuneration linked to results, the activity is labor-related and is not subject to the tax.
The DGT's position has remained constant since 2015. The criterion is systematically based on the assessment of the organization of means, economic risk, and responsibility towards third parties to distinguish independence from labor subordination. No changes are observed in the analytical elements or in the application of the tax.
Analysis based on 75 of 78 rulings with a stated position. Updated 23 September 2026.