Doctrine by topic · DGT Observatory

Maquila: 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 10 rulings · 2018–2024

Current position

Maquila is classified as a provision of services when the value of the materials provided by the client is relevant or when the work does not transform the product into a different good. If the recipient does not have a registered office or permanent establishment in Spain, these services are not subject to IVA (Value Added Tax). Material imports carried out in one's own name by the manufacturer allow for the deduction of the tax.

The DGT's position remains stable regarding the classification of the operation based on the relevance of the materials provided. It has been specified that the contracting of maquila services does not constitute a permanent establishment if an adequate structure of human and technical resources does not exist. The doctrine clearly distinguishes between the delivery of goods and the provision of services according to the degree of transformation.

Turning points

  1. V0824-19

    Establishes that if the value of the active ingredient provided by the client exceeds that of the manufacturer's materials, the operation is a provision of services.

  2. V1618-22

    Clarifies that the mere fact of contracting maquila services does not determine the existence of a permanent establishment.

Analysis based on 10 of 10 rulings with a stated position. Updated 29 September 2026.

Rulings on this topic

12
V3157-23 5 Dec 2023

French company's coating services subject to Spanish VAT

SG de Impuestos sobre el Consumo
adquisición intracomunitariaestablecimiento permanenteprestación de serviciosentrega de bienessujeto pasivo LIVA — Ley 37/1992 del IVA art. 4.unoLIVA — Ley 37/1992 del IVA art. 5.uno
Affects CompanyExpat · Non-residentIndividual

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