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Zero Percent 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 36 rulings · 2020–2022

Current position

The 0% VAT rate applies to goods included in the Annex of the current regulations, complying with both the CN code and the product description. The recipient must be a Public Law entity, clinic, hospital center, or private entity of a social nature. The operations must be documented in an invoice as exempt.

The DGT's position has remained stable since the implementation of the measure in 2020. The requirement for dual compliance has been maintained: the exact match of the CN code and the description of the good, along with a subjective scope restricted to public entities, clinics with inpatient regimes, or social entities.

Turning points

  1. V2814-20

    Specifies that the concept of a clinic or hospital center includes those centers where research or teaching is practiced.

Analysis based on 34 of 36 rulings with a stated position. Updated 23 September 2026.

Rulings on this topic

24
V2647-20 13 Aug 2020

Zero VAT rate on masks depends on product classification and recipient type

SG de impuestos sobre el Consumo
tipo del cero por cientoentidades de derecho públicocentros hospitalariosnomenclatura combinadaentidades de carácter social LIVA — Ley 37/1992 del IVA art. 4.1LIVA — Ley 37/1992 del IVA art. 5.1
Affects CompanyExpat · Non-residentIndividual

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