Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The movement of products under a suspensive regime requires documentation proving their tax status, such as electronic administrative or commercial documents depending on the product. In the case of liquids for electronic cigarettes, shipments from the Peninsula and Balearic Islands to the Canary Islands are treated similarly to an export. For the latter, the movement must be covered by an electronic administrative document through the EMCS system.
The DGT's position remains stable regarding the need to prove the tax status of products through commercial or administrative documentation. The evolution shows a specialization in document management according to the type of product and its destination, moving from general criteria on tax warehouses to the requirement of electronic systems such as the EMCS for specific products.
Turning points
Establishes that liquids for electronic cigarettes to the Canary Islands require an electronic administrative document and the use of the EMCS system.
Analysis based on 47 of 49 rulings with a stated position. Updated 23 September 2026.