How the DGT's position has evolved
Current position
The obligation to withhold falls on the payer whenever they are an obligated party under the regulations and the income is subject to said obligation. It is not mandatory for the withholding to appear on the invoice, although it is possible to include it. The obligated party must issue a certificate proving the withholdings made.
The DGT's position remains constant in defining the elements necessary for the obligation to withhold. Recent rulings focus on specifying that the inclusion of the withholding in the invoice is optional and on the payer's obligation to issue certificates of the withholdings performed.
Analysis based on 43 of 44 rulings with a stated position. Updated 23 September 2026.