How the DGT's position has evolved
Current position
The route sales system for products with an exemption or reduced rate requires compliance with control requirements, validation of delivery notes, and the issuance of delivery notes. In the case of provisioning, the exception for not using an electronic administrative document is only valid for journeys of 50 kilometers or less. For aviation fuels, the exemption is justified through delivery receipts containing data on the supplier, the recipient, and the provisioning.
The DGT's position remains stable regarding the need for supply control. The distance limits for the exemption from electronic documents have been specified, and the documentary requirements for specific sectors, such as aviation, have been detailed.
Turning points
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Establishes that the direct supply system is limited to supplies from a factory or tax warehouse, excluding those made from fiscal warehouses.
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Introduces the 50-kilometer limit to allow provisioning without an electronic administrative document.
Analysis based on 16 of 18 rulings with a stated position. Updated 25 September 2026.