How the DGT's position has evolved
Current position
If acting in one's own name, two independent supplies are produced: that of the original supplier to the professional and that of the professional to the end customer. In this scenario, the professional must charge VAT on the total amount of the transaction. It is not appropriate to treat the amounts as disbursements if the requirements of acting in the name and on behalf of the client through an express mandate and invoices in the client's name are not met.
The DGT's position remains constant regarding the distinction between acting in one's own name or on behalf of another. The rulings confirm that acting in one's own name implies the existence of two distinct VAT operations, whereas acting on behalf of another is classified as mediation or intermediation.
Analysis based on 53 of 57 rulings with a stated position. Updated 23 September 2026.