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Location of the Supply: 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 11 rulings · 2014–2023

Current position

The location of event organization services depends on whether they are configured as a single supply of linked elements or as isolated services. For services provided by electronic means, such as automated translation, the location is situated in the territory of the recipient with a VAT number through the reverse charge mechanism. Online teaching services are only exempt if there is direct communication between teacher and student and they form part of an official plan.

The DGT's position remains stable regarding the distinction between complex event organization services and isolated services. The evolution shows a shift towards resolving doubts about the nature of digital services (teaching and translation) and their location through the reverse charge rule.

Turning points

  1. V2850-21

    Distinguishes between automated online teaching services (electronic services) and exempt educational services based on teacher-student communication.

  2. V1079-23

    Defines that automated translation via web or application is a service provided by electronic means, applying the reverse charge mechanism for recipients with a VAT number.

Analysis based on 11 of 11 rulings with a stated position. Updated 27 September 2026.

Rulings on this topic

11
V0568-16 10 Feb 2016

VAT location for vessel repairs depends on the recipient's status

SG de Impuestos sobre el Consumo
localización de la prestaciónempresario o profesionalembarcaciones de recreofactura simplificadasujeción al impuesto LIVA — Ley 37/1992 del IVA art. 22LIVA — Ley 37/1992 del IVA art. 69
Affects CompanyExpat · Non-residentIndividual

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