Doctrine by topic · DGT Observatory

Reseller of Goods: 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 · 2016–2026

Current position

The reduced VAT rate of 10% applies to the delivery of works of art made by their author or by entrepreneurs other than resellers who have borne the tax on the previous acquisition. If the commercial company is not the author and has not borne the tax on the acquisition or importation of the work, it must apply the general rate of 21%. For a good to be considered a work of art, it must meet specific requirements such as uniqueness or limited editions.

The DGT's position remains constant throughout the sequence. No changes are observed in the interpretation of the requirements for applying the reduced rate of 10% versus the general rate of 21% in resale activities. The rulings are limited to applying the same criterion to different types of goods (ceramics, sculptures, tapestries).

Analysis based on 8 of 8 rulings with a stated position. Updated 13 October 2026.

Rulings on this topic

8
V0059-16 12 Jan 2016

Sculpture deliveries by non-author companies subject to 21% VAT

SG de Impuestos sobre el Consumo
tipo impositivo reducidoobras de arteautoríarevendedor de bienesobra colectiva LIVA — Ley 37/1992 del IVA art. 91.uno.4LIVA — Ley 37/1992 del IVA art. 136.1.2
Affects CompanyExpat · Non-residentIndividual

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