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Services Provided by Electronic Means: 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 Medium confidence 19 rulings · 2014–2026

Current position

Services provided by electronic means are governed by the localization rules of Article 70 of Law 37/1992. Streaming is classified as such, whereas communication via email for the delivery of results does not grant this status. In telematic healthcare services, the IVA (Value Added Tax) exemption is maintained if the requirements regarding the sanitary nature and the professional qualification of the provider are met.

The DGT maintains a clear distinction between purely electronic services, such as streaming or file downloading, and services that use telematic means but are not services provided by electronic means, such as healthcare or music production. No change in criterion is observed, but rather a constant application of the localization and exemption rules according to the nature of the service.

Analysis based on 17 of 19 rulings with a stated position. Updated 25 September 2026.

Rulings on this topic

19
V3007-14 5 Nov 2014

21% VAT rate applies to the leasing of devices for digital book use

SG de Impuestos sobre el Consumo
tipo impositivosoporte físicoservicios por vía electrónicacesión de usolibros electrónicos LIVA — Ley 37/1992 del IVA art. 90.1LIVA — Ley 37/1992 del IVA art. 91.2.1.2º
Affects CompanyExpat · Non-residentIndividual

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