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Liquefied Natural Gas: 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

Refined position High confidence 8 rulings · 2014–2024

Current position

The treatment of IVA (Value Added Tax) depends on the physical state of the gas at the time of sale. If the LNG is in a liquid state, the general rules for the supply of goods apply. If the gas has already been regasified and is supplied via a network or pipeline, the special rule of article 68.six of the IVA Law applies.

The DGT's position has moved from addressing aspects of the Hydrocarbons Tax and exemptions for storage (DDA) to focusing on the determination of the tax rate and the applicable supply rule. The most recent rulings precisely delimit the application of the special supply rule based on whether the product is liquid or gaseous.

Turning points

  1. V2189-22

    Specifies that the reduced rate of 5% applies to natural gas, including liquefied or compressed gas, without regulatory distinction between them.

  2. V1893-24

    Establishes the operational distinction between the general supply rules for liquid LNG and the special rule for regasified gas supplied via a network.

Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8

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