How the DGT's position has evolved
Current position
Services provided by external collaborators are exempt from IVA (Value Added Tax) if they contribute to the approach of the parties through customer acquisition, advisory services, or work prior to contracting. The mere supply of data regarding potential policyholders or information about products without additional actions to conclude the contract is not considered mediation. Pure back-office activities, claims management, or loss adjusting are also not exempt.
The DGT's position has remained constant since 2018. All analyzed rulings agree that the exemption requires an action to approach the parties that goes beyond the simple supply of information or data. No doctrinal change is observed in the sequence.
Analysis based on 8 of 9 rulings with a stated position. Updated 30 September 2026.