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Advertising: 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 24 rulings · 2014–2026

Current position

Financial mediation is exempt from IVA (Value Added Tax) if the provider is an independent third party performing an active role in bringing the parties together. This activity must go beyond the mere supply of information, advertising, or passive call management, including functions such as advisory services, negotiation of terms, or client filtering. Furthermore, the service being mediated must be previously taxable and exempt.

The DGT's position remains constant in the distinction between exempt mediation and taxable advertising. Throughout the rulings, the need for the mediator to provide added value through client analysis or filtering has been reinforced to differentiate it from the simple supply of information or advertising.

Turning points

  1. V2272-22

    Introduces the requirement that the service being mediated must be previously taxable and exempt for the mediation to be exempt.

Analysis based on 23 of 24 rulings with a stated position. Updated 24 September 2026.

Rulings on this topic

24

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