How the DGT's position has evolved
Current position
To correct unduly assessed amounts, the taxpayer may opt for the self-assessment rectification procedure or regularize them in subsequent tax returns. In the case of services provided electronically to entrepreneurs without a permanent establishment in Spain, the transaction is not subject to IVA (Value Added Tax) in Spanish territory.
The DGT does not present a single doctrinal evolution, as the rulings analyze entirely disparate scenarios of undue income (IBI, disability, inheritance, IRPF, IVA). There is no common doctrinal trend, but rather specific responses to concrete cases of rectification or refund.
Analysis based on 28 of 28 rulings with a stated position. Updated 24 September 2026.