How the DGT's position has evolved
Current position
The obligation to file Form 179 rests exclusively with the intermediary who receives remuneration or a commission for achieving the effective contracting between the assignor and the assignee. If the manager holds a sublease right, they act as the assignor and not as an intermediary. In the case of using collaborative platforms, the reporting obligation corresponds to the platform and not to the manager acting through it.
The DGT's position has remained constant since 2019, defining the intermediary under a legal sense based on the receipt of remuneration for the result. No changes have been observed in the interpretation of the reporting obligation, maintaining the distinction between the assignor (holder of the right) and the collaborative platform.
Analysis based on 15 of 15 rulings with a stated position. Updated 26 September 2026.