How the DGT's position has evolved
Current position
The location of operations depends on the application of general or special rules according to the nature of the service and the status of the recipient. For services provided to businesses, the location of the recipient prevails, whereas for individuals, specific rules apply, such as those for electronically supplied services. In intra-Community acquisitions, the right to deduct tax amounts for goods sent outside the territory requires proof of transport and prior payment of the tax.
The DGT's position remains stable in the application of the location rules set out in Articles 69 and 70 of the IVA (Value Added Tax) Law. No doctrinal change is observed, but rather a constant application of differentiated criteria for services, goods, and intra-Community acquisitions according to current regulations. The analyzed rulings simply apply the law to various scenarios without altering the reference framework.
Analysis based on 37 of 38 rulings with a stated position. Updated 16 September 2026.