Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The place where the activity is carried out is the municipality where the establishment from which the services are provided is located. For commercial or service activities, the existence of a physical premises or establishment is required for the activity to be considered as being exercised in said municipality. There is no obligation to register in the IAE (Tax on Economic Activities) in municipalities where services are provided without having a physical establishment.
The DGT's position remains constant in determining the place where the activity is carried out based on the physical location of the establishment. The rulings confirm that the obligation to register in the IAE is linked to the existence of premises or management centers. No changes are observed in the doctrine regarding the need for a physical establishment for municipal taxation.
Turning points
It is established that the vessel itself may be considered an establishment if the company does not have another physical location in Spain.
Analysis based on 21 of 22 rulings with a stated position. Updated 24 September 2026.