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Technical 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 9 rulings · 2014–2022

Current position

Technical services are classified in the IAE (Economic Activities Index) according to their material nature and the activity actually performed. In the scope of IVA (Value Added Tax), technical services directly related to real estate are located where the real estate is situated. Likewise, the provision of technical services may be considered a royalty if it falls within said definition, regardless of the transfer of technology.

The DGT's position is stable and has been applied in a fragmented manner to different areas. Coherence has been maintained regarding the location of technical services linked to real estate and in the classification of heading 843.9 for activities that do not fit into other specific categories.

Turning points

  1. V4699-16

    Establishes that technical services or technical assistance are included in the concept of a royalty, regardless of whether there is a transfer of technology.

  2. V2574-20

    Specifies that the preparation of projects for third parties without executing the work constitutes a distinct technical services activity that requires registration under heading 843.

Analysis based on 8 of 9 rulings with a stated position. Updated 30 September 2026.

Rulings on this topic

11

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