Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
To apply the reduced rates in Ceuta or Melilla, the operator must have tax residence and be truly established in said territories. Real establishment is a matter of fact that the Administration must assess on a case-by-case basis. As reasonable guidelines, it is required that more than 50% of the workforce and the payroll reside and work at the local headquarters, and that intra-group services do not exceed 50% of the total costs.
The DGT's position has moved from establishing general requirements for raffles and sweepstakes to defining specific criteria for the application of reduced rates in Ceuta and Melilla. Since 2020, the doctrine has focused on the requirement of real establishment through the simultaneous fulfillment of three quantitative guidelines regarding workforce, payroll, and intra-group services.
Turning points
Introduces the criteria for real establishment for reduced rates, requiring that more than 50% of the workforce, the payroll, and intra-group services meet specific thresholds in Ceuta or Melilla.
Analysis based on 11 of 11 rulings with a stated position. Updated 27 September 2026.