How the DGT's position has evolved
Current position
A bonded warehouse must be authorized to receive, store, and distribute products with the tax accrued under reduced rates or exemptions. If the product is acquired with the tax already accrued and charged, the requirements to operate as a bonded warehouse are not met. Excise Duty regulations do not contemplate the figure of commercial intermediaries or specific conditions for sales to service stations.
The DGT's position does not show a coherent thematic evolution, as the rulings deal with different matters such as Form 548, the classification of alcohol, the authorization of hydrocarbon depots, or the winery regime. There is no common thread that allows for the identification of a change in criterion, but rather a dispersion of responses on various aspects of excise duties.
Analysis based on 21 of 22 rulings with a stated position. Updated 25 September 2026.