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Professional: 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

Stable position High confidence 25 rulings · 2014–2026

Current position

VAT only taxes the supply of goods and the provision of services carried out by entrepreneurs or professionals in the course of their activity. Operations carried out by private individuals, on a one-off, isolated basis and without intention of continuity, are not subject to the tax. For taxation to apply, there must be an intention to intervene in the production of goods or services through the organization of means.

The DGT's position remains constant throughout the sequence. The criterion establishes that VAT liability depends on the status of entrepreneur or professional and on the performance of the operation within the framework of said activity. No changes are observed in the interpretation regarding the lack of taxation for private individuals or isolated acts.

Analysis based on 24 of 25 rulings with a stated position. Updated 24 September 2026.

Rulings on this topic

24
V0079-19 14 Jan 2019

Athletes must make instalment payments of IRPF despite foreign withholdings

SG de Impuestos sobre la Renta de las Personas Físicas
pagos fraccionadosactividad económicaretenciones en el extranjerodoble imposición internacionalexcepción del 70% RIRPF — RD 439/2007, Reglamento del IRPF art. 109LIRPF — Ley 35/2006 del IRPF art. 79
Affects CompanyExpat · Non-residentIndividual

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