Doctrine by topic · DGT Observatory

Chain Sales: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

← DGT Observatory

How the DGT's position has evolved

Settled doctrine High confidence 23 rulings · 2015–2024

Current position

In chain sales, the exemption under Article 21 of Law 37/1992 applies only to the delivery directly linked to the export transport. For the first delivery to be exempt, the supplier must appear as the exporter on the SAD (Single Administrative Document) or the non-established purchaser must carry out the transport. Successive deliveries following the exempt operation are considered not subject to VAT.

The DGT's position remains constant in its interpretation of the link to transport for the exemption in chain sales. Throughout the rulings, it has been reiterated that the exemption applies to the delivery linked to the outward transport and that the status of exporter is determined by the ability to decide on the departure of the goods. No changes in criterion are observed, but rather a uniform application of the regulations.

Turning points

  1. V0205-19

    Specifies that the status of exporter is determined by the ability to decide on the departure of the goods, which must be proven through commercial agreements such as INCOTERMS.

Analysis based on 23 of 23 rulings with a stated position. Updated 24 September 2026.

Rulings on this topic

23
V3119-21 14 Dec 2021

IVA deductions cannot be claimed under equivalence surcharge regime

SG de Impuestos sobre el Consumo
recargo de equivalenciaexención por exportacióndeducción de cuotascomerciante minoristaduas de exportación LIVA — Ley 37/1992 del IVA art. 4.1LIVA — Ley 37/1992 del IVA art. 4.2
Affects CompanyExpat · Non-residentIndividual

Apply this to your case

VAT advisoryTalk to the team applying this doctrine daily.
Talk to the tax teamWe check whether this criterion affects you and what it means in your situation.
Email
Contact