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Discount: 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 · 2014–2026

Current position

Discounts and rebates do not form part of the VAT (IVA) taxable base if they are justified and granted prior to or simultaneously with the transaction. If the discount is granted subsequently, it is necessary to modify the taxable base and rectify the tax amounts through a credit note. Discount vouchers are considered discounts granted at the time of the transaction and not bonuses.

The DGT's position remains stable regarding the treatment of discounts granted prior to or simultaneously with the transaction. Clarifications have been added regarding the manufacturer's ability to reduce its taxable base through discounts reimbursed to the end customer and the nature of discount vouchers.

Turning points

  1. V0919-22

    Allows the manufacturer to reduce its taxable base by the amount of the discount made to the end customer, excluding the VAT portion of the distributor's sale.

  2. V0883-26

    Clarifies that discount vouchers are not bonuses, but rather discounts granted prior to or simultaneously with the moment of the transaction.

Analysis based on 12 of 14 rulings with a stated position. Updated 26 September 2026.

Rulings on this topic

14

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