Doctrine by topic · DGT Observatory

Importation of Goods: 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

Stable position High confidence 86 rulings · 2014–2026

Current position

The importation of goods from a third territory constitutes a taxable event subject to IVA (Value Added Tax). The importer is the recipient acting in their own name, whether as the purchaser, owner, or consignee. Transport and ancillary services are exempt only if their amount is included in the tax base of the importation. The tax base comprises the consideration for manufacturing services and the ancillary expenses provided for by law.

The DGT's position remains constant regarding the definition of the taxable event and the determination of the tax base. The rulings do not show doctrinal changes, but rather address specific scenarios such as the importation of works of art, inward processing, or the deductibility of quotas at the commencement of activity. The regulations regarding the inclusion of transport costs in the tax base are repeatedly confirmed.

Analysis based on 81 of 86 rulings with a stated position. Updated 21 September 2026.

Rulings on this topic

24
V2485-22 1 Dec 2022

VAT deduction possible for importation as consignatary in own name

SG de Impuestos sobre el Consumo
sujeto pasivoimportación de bienesconsignatario en nombre propioderecho a la deducciónrégimen de maquila LIVA — Ley 37/1992 del IVA art. 5LIVA — Ley 37/1992 del IVA art. 17
Affects CompanyExpat · Non-residentIndividual

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