Doctrine by topic · DGT Observatory

Financial Products: 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 11 rulings · 2018–2024

Current position

Exempt mediation requires the provider to be an independent third party whose functions go beyond the mere supply of information or the receipt of requests. There must be an active element that facilitates contracting, such as advice, profile analysis, or the ability to allow indirect contracting by redirecting the client to the entity. Advertising, the simple supply of data, or the management of formalities without the capacity to influence the contractual relationship are not considered mediation.

The DGT's position has remained constant since 2018, focused on the need for an active element of approaching the parties. Throughout the rulings, it has been specified that the work must allow for direct or indirect contracting, including the redirection to the entity as a facilitating element. No changes in criterion are observed, but rather a reiteration of the requirements of independence and substantive activity.

Turning points

  1. V1138-19

    Specifies that activity on websites constitutes mediation if the client can enter into the contract directly or indirectly at the end of the process.

  2. V1878-24

    Confirms that the redirection of the client to the entity to allow indirect contracting constitutes an active element that facilitates the conclusion of the contract.

Analysis based on 11 of 11 rulings with a stated position. Updated 28 September 2026.

Rulings on this topic

11
V1138-19 24 May 2019

Mediation for indirect online loan contracting may be exempt from VAT

SG de Impuestos sobre el Consumo
mediaciónexenciónproductos financieroscontratación indirectasuministro de información LIVA — Ley 37/1992 del IVA art. 20.Uno.18º.m)LIVA — Ley 37/1992 del IVA art. 20.Uno.18º.c)
Affects CompanyExpat · Non-residentIndividual

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