How the DGT's position has evolved
Current position
Mediation services provided on behalf of others are considered services whose location is governed by the location of the recipient. If the recipient is an entrepreneur or professional with a registered office or establishment in Spain, the transaction is subject to IVA (Value Added Tax) in Spanish territory. The taxable base for mediation is the commission that the intermediary deducts from the main transaction.
The DGT's position remains constant regarding the location of mediation services through the application of the general rules for business recipients. No doctrinal changes are observed in the series, except for the inclusion of an exemption case for commissions for cash withdrawals at ATMs.
Turning points
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Introduces a specific exemption for commissions for the withdrawal of funds at ATMs by considering them operations relating to payment cards.
Analysis based on 25 of 26 rulings with a stated position. Updated 24 September 2026.