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Consignee: 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 14 rulings · 2015–2024

Current position

The consignee acting in their own name holds the status of importer and is a taxable person for IVA (Value Added Tax). To exercise the right to deduction, they must be a businessperson or professional and use the goods in taxable transactions. If they appear in the SAD (Single Administrative Document) as the recipient or consignee acting in their own name and on their own account, they are the debtor of the import duties.

The DGT's position remains constant throughout the analyzed sequence. Since 2017, the administration has reiterated that the consignee is a taxable person for importation whenever they act in their own name. No changes in criterion are observed, but rather a systematic confirmation of the consignee's nature as an importer and debtor of the tax obligation.

Analysis based on 14 of 14 rulings with a stated position. Updated 26 September 2026.

Rulings on this topic

14
V5476-16 28 Dec 2016

Crew taxi transport services are not exempt from VAT

SG de Impuestos sobre el Consumo
exenciónprestación de serviciosnecesidades directas de los buquesconsignatariosujeto pasivo LIVA — Ley 37/1992 del IVA art. 4.UnoLIVA — Ley 37/1992 del IVA art. 5
Affects CompanyExpat · Non-residentIndividual

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