How the DGT's position has evolved
Current position
Liability for IVA (Value Added Tax) depends on the location of the recipient and the nature of the service. Services provided to entrepreneurs without a permanent establishment in Spain are not subject to the tax. In mediation services, liability is determined by the location of the main operations in which the mediator intervenes.
The DGT's position does not show a single doctrinal evolution, as the rulings address different and heterogeneous liability scenarios. A constant application of the rules of location and the status of entrepreneur according to the organizational structure and the residence of the recipient is observed.
Turning points
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Establishes three specific indicators to determine liability through the analysis of independence or subordination: organization of means, assumption of economic risk, and responsibility towards third parties.
Analysis based on 59 of 66 rulings with a stated position. Updated 31 August 2026.