How the DGT's position has evolved
Current position
Deliveries of movable goods that require transport are understood to be made within the territory of application of VAT when the dispatch or transport begins in said territory. If the making available occurs outside of Spain or the transport begins in a third territory or another Member State, the operation is not subject to Spanish VAT. The determination of the tax shall correspond to the regulations of the State where the delivery takes place.
The position of the DGT remains constant throughout the analyzed sequence. The criterion focuses on the place where the transport or the making available begins to determine tax liability. No changes in doctrine are observed, but rather a reiteration that the start of transport in Spanish territory is the determining factor for VAT liability.
Analysis based on 9 of 10 rulings with a stated position. Updated 28 September 2026.