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Zero Percent Tax 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

Stable position High confidence 10 rulings · 2020–2023

Current position

The 0% rate applies to natural products obtained directly from crops or after simple handling or preservation operations that do not alter their original characteristics, such as chopping. For goods listed in the Annex of the COVID-19 regulations, the recipient must be a Public Law entity, a clinic or hospital center (with an inpatient regime), or a private entity of a social nature. The product must comply with both the CN code and the description in the corresponding Annex.

The DGT's position has maintained a constant line in the application of the 0% rate for healthcare goods, focusing on the nature of the recipient and the inpatient regime of the centers. Subsequently, the doctrine has shifted towards the definition of natural products for food, establishing that simple handling does not alter said condition.

Turning points

  1. V2667-21

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

  2. V0502-23

    Introduces the criterion of natural products for food, defining them as those obtained directly from crops or after simple handling operations.

Analysis based on 10 of 10 rulings with a stated position. Updated 28 September 2026.

Rulings on this topic

10
V0111-23 1 Feb 2023

Zero-rated VAT supplies on basic goods allow for the deduction of input tax

SG de Impuestos sobre el Consumo
tipo impositivo del cero por cientoderecho a la deducciónoperaciones sujetas y no exentasregla de la prorrataproductos naturales LIVA — Ley 37/1992 del IVA art. 4.UnoLIVA — Ley 37/1992 del IVA art. 5.Uno
Affects CompanyExpat · Non-residentIndividual

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