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Exempt Operation: DGT doctrinal evolution

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

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How the DGT's position has evolved

Settled doctrine High confidence 9 rulings · 2014–2024

Current position

The rebilling of insurance is considered a transaction subject to and exempt from IVA (Value Added Tax) as long as the exact cost of the premium is passed on to the client without applying margins. If the invoiced amount differs from the insurer's cost, the transaction is considered a service provision subject to the general rate. In the case of housing, the delivery is subject to IVA if it is classified as a first delivery due to rehabilitation works, remaining exempt if it is a subsequent delivery.

The DGT's position remains constant in the distinction between expenses incurred on behalf of others and the rebilling of exact costs. In the insurance field, the 2019 and 2022 rulings confirm that the exemption depends on the absence of a commercial margin. No doctrinal change is observed, but rather a reiteration of criteria regarding the independence of the insurance provision from leasing or renting.

Turning points

  1. V0008-19

    Establishes that the rebilling of insurance is exempt if the exact cost is passed on without margins, distinguishing it from a single transaction subject to tax if the amount varies.

  2. V2410-24

    Specifies that the delivery of housing is subject to tax if it is considered a first delivery due to rehabilitation works, conditioning the deductibility of the IVA for said works.

Analysis based on 9 of 9 rulings with a stated position. Updated 29 September 2026.

Rulings on this topic

9

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