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Independent Third Party: 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 15 rulings · 2014–2025

Current position

Financial mediation is exempt if the provider is an independent third party who brings the parties together for a future contract. Their work must go beyond the mere provision of information or the receipt of requests, participating actively in the negotiation. No exemption exists if the activity is limited to advisory services, investment evaluation, or due diligence. Independence requires that the mediator be perceived as an entity with its own organization and without dependency links to the parties.

The DGT's position remains constant in defining the requirements for the exemption. Throughout the rulings, the scope of independence and the distinction between mediation and advisory services have been further specified. The doctrine has moved from requiring work that exceeds the provision of information to detailing that active participation in negotiation is the differentiating element compared to financial advisory services.

Turning points

  1. V3349-19

    Specifies the concept of independence by requiring that the mediator be perceived as an entity with its own legal personality and organization.

Analysis based on 14 of 15 rulings with a stated position. Updated 26 September 2026.

Rulings on this topic

15

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