How the DGT's position has evolved
Current position
An operation is considered accessory when it follows the taxation regime of the principal operation due to being linked to it. This applies to licenses linked to land, design phases in works of art, or packaging bags for bulk products. If the operation has autonomy or is carried out by different parties, it is taxed independently.
The DGT maintains a constant position on the concept of an accessory operation, applying it to various sectors such as real estate, art, consumer goods, and services. No doctrinal change is observed, but rather an application of the principle of accessoriness to increasingly heterogeneous cases. The key distinction lies in the direct link to the principal operation and the absence of economic autonomy.
Analysis based on 16 of 19 rulings with a stated position. Updated 25 September 2026.