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Securities: 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 8 rulings · 2014–2022

Current position

Settlement, clearing, and management services for securities are exempt from IVA (Value Added Tax) when they create, modify, or extinguish rights, regardless of whether the provider is a financial institution. Financial advisory services do not benefit from this exemption as they do not constitute a securities deposit or management operation. In the scope of IRPF (Personal Income Tax), advisory income is considered income from economic activities.

The DGT's position remains stable regarding the exemption of essential securities services, focusing the criterion on the nature of the operation rather than the subject. The limits of the exemption have been specified by explicitly excluding financial advisory from this scope. The doctrine confirms that the exemption applies to settlement and clearing functions that affect the legal status of the parties.

Turning points

  1. V3943-15

    Establishes that the exemption for financial services applies regardless of whether the provider is a financial institution, based on the type of operation.

  2. V2174-20

    Delimits the scope of the exemption by determining that financial advisory is not a securities deposit or management operation and, therefore, is not exempt from IVA.

Analysis based on 7 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8
V3192-14 27 Nov 2014

Coupon payments on bonds are exempt from VAT

SG de Impuestos sobre el Consumo
operaciones financierasbonocupónexencióntítulos valores LIVA — Ley 37/1992 del IVA art. 20.Uno.18.a
Affects CompanyExpat · Non-residentIndividual

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