Doctrine by topic · DGT Observatory

Re-invoicing of Expenses: 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 68 rulings · 2014–2026

Current position

The re-invoicing of expenses carried out within the framework of a lease agreement is considered an accessory provision of the principal one. Therefore, these amounts form part of the taxable base of the lease and must receive the same tax treatment as the latter. They are only considered disbursements (suplidos), and therefore not subject to IVA (Value Added Tax), if they are paid on behalf of and for the account of the client with an express mandate and an invoice issued in the client's name.

The DGT's position has remained constant in considering re-invoicing as an operation subject to IVA. The evolution focuses on technical precision to distinguish between the re-invoicing of expenses (which follows the nature of the principal operation) and disbursements (which fall outside the tax if they meet the requirements of mandate and direct invoicing).

Turning points

  1. V1850-22

    Establishes the distinction between a single and independent expense, which is an autonomous operation, and an accessory expense, which receives the treatment of the principal provision.

Analysis based on 67 of 68 rulings with a stated position. Updated 22 September 2026.

Rulings on this topic

24
V0500-26 5 Mar 2026

Crew expenses refacturing liable to 21% VAT in Spain

SG de Impuestos sobre el Consumo
consignataria de buquesrefacturación de gastosexención por buquesnecesidades directas del buquenavegación internacional LIVA — Ley 37/1992 del IVA art. 4LIVA — Ley 37/1992 del IVA art. 5
Affects CompanyExpat · Non-residentIndividual
V3061-23 23 Nov 2023

Exact cost recovery of insurance to a subsidiary may be VAT-exempt

SG de Impuestos sobre el Consumo
suplidosrefacturación de gastosprestación de serviciosoperación exentabase imponible LIVA — Ley 37/1992 del IVA art. 4.1LIVA — Ley 37/1992 del IVA art. 4.2
Affects CompanyExpat · Non-residentIndividual

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