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Successive Performance Operations: 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 · 2020–2026

Current position

In successive performance operations, such as the supply of electricity, the applicable tax rate is the one in force at the time of accrual. Accrual occurs when the portion of the price comprising each charge becomes due, according to the terms of the contract. This moment of exigibility is independent of the period in which the consumption took place or the moment of payment.

The DGT's position remains constant throughout the analyzed sequence. The criterion establishes that the applicable rate depends on the regulations in force at the time each part of the price becomes due, regardless of when the actual consumption occurred. No changes in doctrine are observed, but rather a reiteration of the same accrual principle.

Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8
V1005-25 12 Jun 2025

VAT rate for electricity supply depends on when price becomes due

SG de Impuestos sobre el Consumo
devengosuministro eléctricooperaciones de tracto sucesivoexigibilidad del precioprestación de servicios LIVA — Ley 37/1992 del IVA art. 75.1.2LIVA — Ley 37/1992 del IVA art. 75.1.7
Affects CompanyExpat · Non-residentIndividual

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