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Freight Forwarder: 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 17 rulings · 2014–2024

Current position

Transport services are exempt from IVA (Value Added Tax) when related to exports of goods outside the Community. The exemption applies if services are provided to exporters, recipients, customs representatives, or freight forwarders acting on their behalf. The service must be performed from the dispatch of the goods to a point outside the Community or a port/border area. The exit of the goods must occur within a period of three months.

The DGT's position remains constant regarding the core of the exemption for freight forwarders acting on behalf of others. Throughout the sequence, the administration has maintained the exclusion of the exemption when the intermediary acts on their own behalf. The latest ruling adds precision regarding the geographical scope of the dispatch and the deadline for the exit of the goods.

Turning points

  1. V0074-24

    Specifies that transport must be performed from the dispatch to a point outside the Community or a port/border area and establishes a three-month period for the exit of the goods.

Analysis based on 17 of 17 rulings with a stated position. Updated 25 September 2026.

Rulings on this topic

17

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