How the DGT's position has evolved
Current position
The provision of services is considered to be carried out within the territory of application of the tax when the recipient is an entrepreneur or professional who has their registered office of economic activity or a permanent establishment in said territory. This criterion applies regardless of the location of the provider or the place from which the service is provided. In the case of travel agencies acting on their own behalf, the provision is located where the agency has its registered office or permanent establishment.
The DGT's position remains constant throughout the sequence. Consultations repeatedly confirm that the registered office of the recipient's economic activity determines the location of the service when the recipient is an entrepreneur or professional. No changes in criterion are observed, but rather a uniform application of the localization rule based on the client's registered office.
Analysis based on 15 of 15 rulings with a stated position. Updated 26 September 2026.