How the DGT's position has evolved
Current position
The suspensive regime allows the movement of products without the tax accrual as long as they remain in tax warehouses or are subject to guaranteed shipments. In the case of imported flavorings with multiple applications, there is no taxable event, but their mixing for vaping liquids constitutes manufacturing and triggers the tax upon leaving the factory. The responsibility for payment lies with the warehouse keeper if the recipient is not an authorized operator.
The DGT's position remains constant in the application of suspensive regimes to avoid premature accrual in warehouses and guaranteed shipments. No doctrinal change is observed, but rather an application of specific criteria for different products such as hydrocarbons, alcohol, or flavorings. The doctrine focuses on the nature of the establishment and the correct identification of the operators.
Turning points
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Establishes that flavorings with multiple applications do not generate the taxable event, but their mixing for vaping liquids does constitute manufacturing with accrual upon leaving the factory.
Analysis based on 96 of 100 rulings with a stated position. Updated 23 September 2026.