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Financial 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 8 rulings · 2016–2022

Current position

Financing operations, such as the granting of loans with pledge, the assignment of credits, or the management of call options on loans, are considered exempt services as they constitute the granting of credit or loans. The financial nature of the operation prevails over the technical support used, such as mobile applications acting as means of payment. They are not considered deliveries of goods when the entirety of the benefits and burdens of ownership are not transferred.

The DGT's position remains constant in classifying various structures as exempt financial operations. A consistent application of the exemption is observed for services that, although using technological means or rights over loans, maintain the essence of granting credit or loans. The doctrine clearly distinguishes between the provision of the exempt financial service and other administrative or management services that remain taxable.

Turning points

  1. V0116-17

    Clarifies that in forfaiting, the discount is a reflection of risk and not consideration for a service, separating the exemption from administrative management.

  2. V1029-17

    Establishes that commissions for the use of mobile applications are exempt if the application functions as a means of payment equivalent to credit cards.

  3. V1627-17

    Determines that the premium of a call option on loans is exempt due to having an underlying of a financial nature.

Analysis based on 7 of 8 rulings with a stated position. Updated 1 October 2026.

Rulings on this topic

8

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