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Sales Commission: 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 9 rulings · 2014–2026

Current position

In sales commission operations where the commission agent acts on their own behalf, two simultaneous deliveries of goods occur. The tax base for the transfer from the principal to the commission agent is the agreed consideration minus the commission. In both cases, VAT (IVA) must be applied to the corresponding tax base.

The DGT's position remains stable regarding the definition of accrual, stating that it occurs when the commission agent delivers the goods to the final customer. The evolution focuses on the application of different tax rates depending on the nature of the product (supplies, natural products, or art) and precision regarding the tax base in models of acting on one's own behalf.

Turning points

  1. V0390-26

    Specifies that in commissions where the agent acts on their own behalf, there are two deliveries of goods and defines the tax base as the agreed consideration minus the commission.

Analysis based on 9 of 9 rulings with a stated position. Updated 30 September 2026.

Rulings on this topic

9

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