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Principal — 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 · 2017–2026

Current position

In commission contracts where the agent acts in their own name, two distinct transfers of goods occur: from the supplier to the agent and from the agent to the principal. The taxable base for the transfer from the agent to the principal is the agreed consideration minus the commission. VAT is accrued when the goods are made available or at the time of the collection of advance payments.

The DGT's position remains constant in identifying two independent deliveries of goods when the agent acts in their own name. Throughout the rulings, the treatment of accrual in the event of advance payments and the determination of the taxable base in the principal-agent relationship has been clarified.

Turning points

  1. V1876-24

    Clarifies that the rule of accrual due to advance payment applies independently to each of the two deliveries of goods.

  2. V0390-26

    Establishes that the taxable base for the transfer from the agent to the principal shall be the agreed consideration minus the commission.

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

Rulings on this topic

9

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