Doctrine by topic · DGT Observatory

Expenses on Behalf of Third Parties: 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 10 rulings · 2014–2026

Current position

In order for travel and accommodation expenses not to be taxed as employment income, the entity must directly make the means of transport and accommodation available to the beneficiary. If there is a reimbursement of expenses without proving the strict necessity for the function, or if amounts are paid for free choice, the amount is considered monetary income subject to withholding. This criterion applies especially when there is no employment or statutory relationship of dependency.

The DGT's position remains constant throughout the sequence. The criterion requires the entity to provide the means directly to prevent the reimbursement from being considered income. No changes are observed in the interpretation of the exemption requirements for different groups.

Analysis based on 10 of 10 rulings with a stated position. Updated 29 September 2026.

Rulings on this topic

10

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