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Telecommunications 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

Settled doctrine High confidence 8 rulings · 2014–2024

Current position

The location of telecommunications services depends on the location of the recipient. For end consumers on mobile networks, it is presumed that the customer is established in the country identified by the telephone code of the SIM card used. If the SIM is foreign, it is presumed that the customer is not in Spain, unless proven otherwise.

The DGT's position remains constant in the application of location rules according to the recipient. The evolution shows a shift from general criteria regarding the location of the entrepreneur toward the implementation of specific technical presumptions, such as the use of the SIM card code to determine the end consumer's residence.

Turning points

  1. V1943-24

    Introduces the presumption of the end consumer's location based on the telephone code of the SIM card used.

Analysis based on 8 of 8 rulings with a stated position. Updated 1 October 2026.

Rulings on this topic

8

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