Doctrine by topic · DGT Observatory

Logistics 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 12 rulings · 2015–2026

Current position

The contracting of logistics services or the use of third-party warehouses does not constitute a permanent establishment. For a permanent establishment to exist, a structure with human and technical resources with a sufficient degree of permanence is required. The activity of a transport organizer or coordinator without its own resources must be declared under heading 756.1 of the IAE (Economic Activities Index).

The DGT's position remains constant in determining permanent establishment, reiterating that the use of logistics services or warehouses is not sufficient for its existence. The doctrine has maintained the need for a structure of human and technical resources with permanence. The latest ruling introduces clarifications regarding registration in the IAE for transport organizers.

Turning points

  1. V5109-26

    Clarifies the registration in the IAE for logistics services, indicating that the activity of a transport organizer or coordinator without its own resources requires heading 756.1.

Analysis based on 11 of 12 rulings with a stated position. Updated 27 September 2026.

Rulings on this topic

12

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