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Mediation Services: 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

Stable position High confidence 14 rulings · 2014–2024

Current position

The VAT exemption for mediation services requires that the activity consists of bringing parties together for the conclusion of a contract. The exemption does not apply to the mere supply of data, advertising services, content management, back-office activities, or services of a logistical or financial nature. In residential leasing, mediation performed by a company is subject to the general rate of 21% if the lessee is a legal entity.

The DGT's position remains stable in delimiting mediation against other support activities. Throughout the rulings, the distinction between effective mediation and the mere supply of information or technical management services has been reinforced. No doctrinal shifts are observed, but rather a constant application of the exemption to direct intermediation and its exclusion in support or automated services.

Turning points

  1. V2500-19

    Specifies that if the interaction on a platform is automated and without human intervention, the service is classified as provided electronically and not as mediation.

  2. V2660-20

    Establishes that functions such as the collection of fees or the negotiation of conditions disqualify the service from being classified as an electronic service, qualifying it instead as mediation acting on behalf of another.

Analysis based on 12 of 14 rulings with a stated position. Updated 26 September 2026.

Rulings on this topic

14
V3010-14 5 Nov 2014

Specific export mediation services may be exempt from VAT

SG de Impuestos sobre el Consumo
servicios de mediaciónexención por exportaciónintermediaciónhecho imponiblereglas de localización LIVA — Ley 37/1992 del IVA art. 21.5.6LIVA — Ley 37/1992 del IVA art. 69.Uno.1
Affects CompanyExpat · Non-residentIndividual

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