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Zero Rate: 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 9 rulings · 2020–2023

Current position

To apply the 0% rate, the product must simultaneously meet two requirements: it must be classified under the codes of the Combined Nomenclature in the Annex and match the description of the good set out therein. The recipient must be a Public Law entity, a clinic or hospital center (centers with an inpatient regime that carry out research or teaching), or a private entity of a social nature.

The DGT's position remains constant in requiring both objective requirements (CN code and description) and subjective requirements (type of recipient). It has been reiterated that the concept of a clinic or hospital center is limited to centers with an inpatient regime that carry out research or teaching, excluding outpatient care centers.

Turning points

  1. V0005-21

    Establishes the need to simultaneously meet two requirements: classification under the Combined Nomenclature code and matching the description in the Annex.

  2. V1166-21

    Specifies that the concept of a clinic or hospital center requires inpatient care and the practice of medical research or teaching.

Analysis based on 9 of 9 rulings with a stated position. Updated 30 September 2026.

Rulings on this topic

9

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