How the DGT's position has evolved
Current position
The collection management of own receivables does not constitute a taxable event for IVA (Value Added Tax). In merger operations, if the absorbing entity carries out activities that combine taxable operations with other exempt ones without the right to deduction, it must apply the pro rata rule to determine its deduction percentage. The right to deduction depends on the exempt operations meeting the requirements of Articles 94 and 105 of the IVA Law.
The sequence does not show a doctrinal evolution on a single concept, but rather addresses various scenarios of exempt operations and pro rata. A constant application of the regulations is observed to determine the right to deduction in activities that do not generate tax debit. There are no changes in criterion, but rather a dispersed application of the law to different scenarios.
Analysis based on 61 of 66 rulings with a stated position. Updated 23 September 2026.