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Commission Agent Acting in One's Own Name: 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 · 2016–2023

Current position

When a commission agent acts in their own name, two distinct deliveries of goods occur: that from the supplier to the commission agent and that from the commission agent to the final customer. Both operations are subject to VAT and accrue when the supplier makes the good available to the commission agent. The tax base for the delivery to the customer shall be the agreed consideration plus the commission.

The DGT's position has remained constant throughout the analyzed sequence. Since 2016, the administration has identified acting in one's own name as the generation of two independent deliveries of goods, maintaining uniform criteria regarding accrual and the tax base.

Analysis based on 9 of 9 rulings with a stated position. Updated 29 September 2026.

Rulings on this topic

9
V1144-22 23 May 2022

Two IVA-taxable supplies when intermediary acts in own name

SG de Impuestos sobre el Consumo
comisionista en nombre propioentrega de bienesprestación de serviciosbase imponibledevengo LIVA — Ley 37/1992 del IVA art. 4.UnoLIVA — Ley 37/1992 del IVA art. 4.Tres
Affects CompanyExpat · Non-residentIndividual

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