Doctrine by topic · DGT Observatory

Deemed operations: DGT doctrinal evolution

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

← DGT Observatory

How the DGT's position has evolved

Settled doctrine High confidence 8 rulings · 2014–2022

Current position

The free delivery of goods and services from business assets is considered a deemed operation equivalent to onerous deliveries and is subject to tax. In the case of goods requiring installation, the location depends on where said installation is carried out, and it may not be considered an intra-Community supply if the cost of the installation is relevant. Likewise, acquisitions deemed to be intra-Community supplies must be included in the recapitulative statement.

The DGT maintains a constant position on the nature of deemed operations, treating free deliveries as taxable operations. No doctrinal change is observed, but rather an application of specific criteria for different scenarios such as self-consumption, the location of installations, or intra-Community acquisitions. The doctrine remains stable regarding the classification of these operations.

Analysis based on 8 of 8 rulings with a stated position. Updated 30 September 2026.

Rulings on this topic

8
V1105-18 27 Apr 2018

VAT exemption does not apply to goods transport under inward processing

SG de Impuestos sobre el Consumo
perfeccionamiento pasivoexención por exportacióntransporte de mercancíasámbito espacial del impuestooperaciones asimiladas LIVA — Ley 37/1992 del IVA art. 4.UnoLIVA — Ley 37/1992 del IVA art. 5.Uno
Affects CompanyExpat · Non-residentIndividual

Apply this to your case

VAT advisoryTalk to the team applying this doctrine daily.
Talk to the tax teamWe check whether this criterion affects you and what it means in your situation.
Email
Contact