How the DGT's position has evolved
Current position
The recipient of the transaction is the natural or legal person who holds the position of creditor in the legal relationship and is obligated to pay the consideration. This condition is independent of who makes the actual payment or who is the economic beneficiary. The invoice must be issued in accordance with the agreed contractual conditions, unless there is a prior agreement of acceptance by the recipient.
The DGT's position has remained constant over time, defining the recipient as the legal subject who is the creditor of the payment obligation. The analyzed rulings repeatedly confirm this criterion, applying it both to the determination of the place of supply and to the validity of the VAT (IVA) deduction. No changes are observed in the substantive definition of the concept.
Analysis based on 25 of 27 rulings with a stated position. Updated 24 September 2026.