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Reseller: 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 41 rulings · 2014–2023

Current position

To hold the status of a fluorinated gases reseller and make exempt purchases, it is mandatory to be registered in the territorial Registry and to provide the Fluorinated Gases Activity Code (CAF) to the seller. Resellers must comply with formal obligations such as maintaining stock records, submitting summary returns (Form 586), and quarterly self-assessments (Form 587). The status of reseller is distinguished from that of the final consumer, the latter being the one who acquires gases for the charging, recharging, or maintenance of equipment.

The DGT's position remains stable regarding the definition of a reseller and the registration requirements for the exemption. Throughout the rulings, the doctrine has specified the formal obligations and stock reporting requirements that these entities must fulfill. No changes are observed in the nature of the concept, but rather an accumulation of control and registration requirements.

Turning points

  1. V0632-14

    Clarifies that businesses acquiring gases for the manufacture, charging, or maintenance of products are not resellers, but final consumers.

  2. V3141-19

    Establishes that the reseller must maintain stock records and submit summary returns and quarterly self-assessments.

Analysis based on 39 of 41 rulings with a stated position. Updated 23 September 2026.

Rulings on this topic

24
V1278-23 16 May 2023

Artworks subject to 21% VAT if acquired under the general regime

SG de Impuestos sobre el Consumo
régimen especial de bienes usadosobjetos de arterevendedorbase imponibletipo impositivo LIVA — Ley 37/1992 del IVA art. 4LIVA — Ley 37/1992 del IVA art. 5
Affects CompanyExpat · Non-residentIndividual

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