How the DGT's position has evolved
Current position
The accrual of IVA (Value Added Tax) in the supply of goods occurs, as a general rule, when the goods are made available to the acquirer. The applicable tax rate is the one in force at the time of said making available. The supply of goods is not understood to have taken place within the territory of application of the tax if the making available does not occur within it.
The DGT's position has remained constant over time regarding the concept of making available as the moment of accrual and the determining factor for the place of supply. The analyzed rulings do not show doctrinal changes, but rather applications of the concept to different scenarios such as works, transport, intra-Community acquisitions, or tax rates.
Analysis based on 52 of 57 rulings with a stated position. Updated 23 September 2026.