How the DGT's position has evolved
Current position
The liability for VAT on a partner's services depends on the existence of a relationship of independence or labor subordination. This is determined through three indicators: the organization of means and schedules, the nature of the remuneration (whether it depends on results or involves economic risk), and responsibility towards third parties. If the partner acts under the company's organizational criteria and does not assume risks, the provision is a labor relationship not subject to the tax.
The DGT's position has remained constant since 2016, applying a three-indicator analysis to distinguish independence from subordination. No changes have been observed in the criteria for assessing working conditions, remuneration, or responsibility. The doctrine has been applied repeatedly and uniformly in all analyzed rulings.
Analysis based on 61 of 64 rulings with a stated position. Updated 23 September 2026.