Doctrine by topic · DGT Observatory

Place of 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

Settled doctrine High confidence 8 rulings · 2014–2020

Current position

Services directly related to real estate are considered to be supplied in the place where said property is located. For the supply to be linked to the real estate, the property must be the essential and basic element of the service. If the real estate is located outside the territory to which the tax applies, the transaction is not subject to IVA (Value Added Tax) in Spain. This classification extends to services subcontracted by the consultant.

The DGT's position on the location of services linked to real estate remains constant throughout the sequence. The rulings confirm that the location of the real estate determines the place of supply, provided that it is the essential element of the service. No changes in criterion are observed, but rather a repeated application of the rule to different assets (buildings, photovoltaic plants, or real estate abroad).

Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8
V0026-20 9 Jan 2020

Services related to real estate outside Spain are not subject to Spanish VAT

SG de Impuestos sobre el Consumo
servicios relacionados con bienes inmuebleslugar de prestacióndeclaración recapitulativaprestación intracomunitaria de serviciossujeto pasivo LIVA — Ley 37/1992 del IVA art. 70.Uno.1ºLIVA — Ley 37/1992 del IVA art. 69.Uno.1º
Affects CompanyExpat · Non-residentIndividual

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