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Collaborating Entities: 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 9 rulings · 2014–2024

Current position

The VAT exemption for travelers requires that the purchaser resides outside the Community and that the goods leave the Community territory. The seller must mandatorily issue the invoice and the electronic refund document (DER) containing the traveler's details and the tax broken down. Authorized collaborating entities manage the collection of the refund, but they do not have the capacity to issue the electronic refund document.

The DGT's position remains constant regarding the existence of two paths for the refund: the general procedure and the special procedure through collaborating entities. The evolution focuses on the digitalization of the process, moving from the mention of invoices processed by Customs to the mandatory use of the electronic refund document (DER).

Turning points

  1. V0564-20

    Introduces the mandatory requirement to document refunds through an invoice and the electronic refund document (DER).

  2. V0936-20

    Clarifies that collaborating entities only manage the collection of the refund and lack the competence to issue the electronic refund document.

Analysis based on 8 of 9 rulings with a stated position. Updated 30 September 2026.

Rulings on this topic

9

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