Doctrine by topic · DGT Observatory

Commercial Mediation: 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 8 rulings · 2014–2023

Current position

The location of commercial mediation services depends on the nature of the recipient and the use of the service. If the recipient is an entrepreneur or professional, the supply is located where they have their registered office or establishment. In cases of mediation on behalf of others, the rule of effective use or exploitation in Spain may apply if the service is effectively used in Spanish territory. For individuals, the location is governed by specific rules depending on the activity or transport.

The DGT's position remains stable regarding location based on the registered office of the entrepreneur recipient. An evolution is observed towards a more rigorous application of the rule of effective use or exploitation in services provided to non-residents. Likewise, the administration has clarified the application of exemptions in specific contexts of export and transport.

Turning points

  1. V0183-15

    Establishes that commercial intermediation and collection intermediation constitute a single supply of commercial mediation services.

  2. V4283-16

    Determines that mediation services related to real estate are located where said real estate is situated.

  3. V1626-22

    Clarifies that mediation on behalf of others may be located in Spain by effective use or exploitation, regardless of whether the recipient carries out taxable operations.

Analysis based on 7 of 8 rulings with a stated position. Updated 30 September 2026.

Rulings on this topic

8

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