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Investment Gold: 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 10 rulings · 2015–2026

Current position

The supply of investment gold is an operation subject to and exempt from IVA (Value Added Tax) when carried out by entrepreneurs or professionals. The sale of fungible tokens representing investment gold is classified as a supply of goods, applying the exemption if the underlying metal is investment gold. In transfers between private individuals, the operation is not subject to IVA, but is subject to ITPAJD (Transfer Tax on Property Transfers and Legal Acts), with the acquirer being the taxable person.

The DGT's position remains constant regarding the application of the exemption for professionals, but it has specified the scope of taxation. It has been clarified that mediation is not exempt if the principal operation is not subject to IVA (as in sales between private individuals) and the exempt treatment has been extended to tokens representing the metal.

Turning points

  1. V0345-22

    Establishes that the mediation service is subject to IVA if the delivery of gold between private individuals is not subject to the tax because it is not carried out by entrepreneurs.

  2. V0078-24

    Determines that the sale of a fungible token backed by gold is a supply of goods and that the operation will be subject to but exempt from tax if the metal is investment gold.

Analysis based on 10 of 10 rulings with a stated position. Updated 28 September 2026.

Rulings on this topic

10

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