Doctrine by topic · DGT Observatory

Insurance Brokerage: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

← DGT Observatory

How the DGT's position has evolved

Settled doctrine High confidence 31 rulings · 2014–2025

Current position

The VAT exemption in insurance brokerage requires that the services seek clients or bring them into contact with the insurer. For an external call center to be considered a broker, it must act as a linked or exclusive agent and perform activities typical of the profession, such as seeking clients for the conclusion of the contract. The mere provision of information, advertising, or back-office activities are not considered exempt.

The DGT has maintained a consistent line regarding the nature of brokerage, requiring that the activity goes beyond the provision of information to qualify for the VAT exemption. Throughout the rulings, it has been specified that brokerage requires actively bringing the parties together, and this analysis has been extended to distribution models such as external call centers.

Turning points

  1. V3050-19

    Establishes that pure 'back office' services or the provision of data without additional action are not exempt, requiring that the client be able to conclude the contract through the medium used.

  2. V0744-25

    Specifies that external call centers meet the exemption if they hold the status of linked or exclusive agents and perform activities typical of the profession.

Analysis based on 28 of 31 rulings with a stated position. Updated 24 September 2026.

Rulings on this topic

24
V0744-25 28 Apr 2025

Call-center insurance agents may be exempt from VAT

SG de Impuestos sobre el Consumo
exenciónmediación de segurosagente vinculadoagente exclusivocall-center LIVA — Ley 37/1992 del IVA art. 20.Uno.16ºLGT — Ley 58/2003 General Tributaria art. 89.1
Affects CompanyExpat · Non-residentIndividual

Apply this to your case

VAT advisoryTalk to the team applying this doctrine daily.
Talk to the tax teamWe check whether this criterion affects you and what it means in your situation.
Email
Contact