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Attachment of Credits: 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 13 rulings · 2014–2022

Current position

Only accrued credits whose maturity date has not yet arrived are attachable, or those involving successive payments for continuous operations or ongoing relationships. It is not possible to attach future credits that have not yet arisen or whose existence is uncertain. The third party has a duty to report on the emergence of new credits susceptible to attachment.

The DGT's position remains constant in the delimitation of attachable credits. Consultations confirm that the attachment falls upon accrued credits that are not yet due or successive payments, always excluding future credits or those of uncertain existence. The doctrine has focused on reinforcing the third party's duty to provide information upon the appearance of new credits.

Turning points

  1. V3033-17

    Establishes that it is not possible to attach future credits that have not yet arisen or of uncertain existence, limiting the attachment to accrued credits with pending maturity.

  2. V2507-18

    Clarifies that it is not possible to attach services whose payment has already been made in advance, as the credit ceases to exist.

Analysis based on 13 of 13 rulings with a stated position. Updated 27 September 2026.

Rulings on this topic

13
V2882-16 22 Jun 2016

Hoteliers must bill machine operators for space leasing

SG de Impuestos sobre el Consumo
cuenta en participacióncesión de espaciocifra de negociossujeto pasivoprestación de servicios LIVA — Ley 37/1992 del IVA art. 4LIVA — Ley 37/1992 del IVA art. 5
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