How the DGT's position has evolved
Current position
The provision of services to non-resident recipients is not subject to IVA if they have neither a registered office nor a permanent establishment in the territory of application. In the case of individuals outside the Community, advisory services are not subject, unless the closing rule regarding effective use or exploitation in Spanish territory applies. For the exemption of exports of goods, it is essential to prove the effective exit of the goods from the Community territory.
The DGT's position remains constant in the application of localization rules according to the location of the recipient or the property. No doctrinal changes are observed, but rather a systematic application of the regulations to determine the taxability or exemption of the tax according to the territory.
Analysis based on 45 of 45 rulings with a stated position. Updated 15 September 2026.