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Deposit Scheme: 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 8 rulings · 2014–2023

Current position

In the deliveries of natural products under a deposit scheme to cooperatives so that they may sell in their own name, the tax accrual occurs when the cooperative effects the sale to the third-party purchaser. The applicable tax rate is the one in force at the time of said accrual. If the consideration is not known at the time of accrual, the taxable person must set it provisionally using well-founded criteria.

The DGT's position has moved from treating the general exemption for goods destined for deposit schemes (2014) to focusing on the moment of accrual in operations with agricultural cooperatives. The 2023 rulings consolidate that accrual occurs upon the final sale to the third party and specify the treatment of unknown consideration and the applicable tax rates according to the timing of the sale.

Turning points

  1. V1566-20

    Establishes that in deliveries under a deposit scheme to cooperatives, the delivery is understood to be made at the moment the cooperative effects the sale to the third-party purchaser.

  2. V0336-23

    Introduces the obligation to provisionally set the consideration using well-founded criteria if the amount is not known at the time of accrual.

Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8

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