Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The importation of goods does not occur while the inward processing regime is in effect; the tax is accrued only upon its completion. The taxable person for the importation is the one acting as consignee in their own name, having the right to deduct the tax amounts incurred even if subsequent operations are exempt. Ownership of the authorization belongs to the company established in the Union that carries out the transformation.
The DGT's position remains constant regarding the nature of the taxable event, focusing the importation on the completion of the regime. Throughout the rulings, aspects regarding the taxable person's capacity for deduction and the ownership of the authorization in assembly processes have been clarified. No changes in criterion are observed, but rather a technical application of the regulations concerning the status of the taxable person and the management of goods.
Turning points
Clarifies that the taxable person for the importation is the consignee in their own name and confirms their right to deduction even if subsequent operations are exempt.
Establishes that ownership of the authorization belongs to the Union company that performs the transformation or assembly.
Analysis based on 16 of 16 rulings with a stated position. Updated 26 September 2026.