How the DGT's position has evolved
Current position
The classification of activities in the IAE (Tax Administration Act) must be based on the true material nature of the operations performed. Registration in a specific heading empowers the performance of the described activity, but does not automatically authorize other complementary activities such as the sale of products or financial services. In cases of industrial processes or energy production, the classification depends on the specific function performed and the location of the plant.
The DGT's position remains constant in its requirement that the heading reflects the economic reality of the activity. Throughout the rulings, a systematic application of the principle of specialty is observed, where registration in a heading does not legitimize the performance of connected activities that are not described. No doctrinal changes are observed, but rather a repeated application of classification criteria according to the nature of the service or product.
Analysis based on 22 of 22 rulings with a stated position. Updated 24 September 2026.