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Exporter: 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 14 rulings · 2015–2023

Current position

The supply of goods is exempt from IVA (Value Added Tax) if the transferor appears as the exporter in the SAD (Single Administrative Document) and the transport outside the Union is linked to said supply. In chain sales, if the first supply meets these requirements, subsequent supplies are considered not subject to the tax. The exemption also applies if the non-established purchaser carries out the shipment appearing as the exporter.

The DGT's position has remained constant over time. The criterion focuses on the link between the transport and the first supply and the necessity for the transferor to be listed as the exporter in the SAD. Subsequent rulings have reinforced the importance of contractual agreements and INCOTERMS in determining said condition.

Turning points

  1. V0205-19

    Establishes that the status of exporter is determined by the power to decide on the exit of the goods, which must be proven through commercial agreements such as INCOTERMS.

  2. V2454-21

    Specifies that the supplier may hold the status of exporter if the parties agree to it contractually and they are responsible for conducting the goods outside the Union.

Analysis based on 14 of 14 rulings with a stated position. Updated 26 September 2026.

Rulings on this topic

14

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