How the DGT's position has evolved
Current position
Manufacturing activity may be carried out directly or by entrusting the material execution to other entrepreneurs following a prior design. In this case, the activity must be classified under the heading of the first section corresponding to the manufactured product. Registration under the manufacturing heading also allows for wholesale, retail, and export.
The DGT's position remains stable regarding the nature of subcontracting as part of economic activity. The doctrine has been maintained that subcontracting the organization or the material execution allows for compliance with economic activity requirements or heading classifications. No changes in criterion are observed, but rather a reiteration of the validity of subcontracting for the management of assets or industrial processes.
Analysis based on 66 of 71 rulings with a stated position. Updated 23 September 2026.