How the DGT's position has evolved
Current position
Supplies that do not constitute an end in themselves for the client, but are rather the means to enjoy a principal service or good, are considered ancillary. These operations do not tax autonomously, but rather follow the regime of the principal operation. The applicable tax rate will be the one corresponding to the principal good or service.
The DGT's position remains constant in the application of the principle of accessoriness. Through the analyzed rulings, it is confirmed that derivative supplies follow the regime of the principal operation, whether in mediation services, installation of materials, financial services, or the delivery of packaging.
Analysis based on 13 of 13 rulings with a stated position. Updated 27 September 2026.