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Canary Islands Special Zone: 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 · 2014–2024

Current position

For intermediation to count towards the ZEC tax base, it must employ information technologies, material or human resources within the ZEC and must not involve the manipulation of goods within the zone. Services received from subsidiaries must be valued at market value. Furthermore, compliance with investment and employment requirements is based on registration in the Official Registry of ZEC Entities and allows for the counting of workers in business successions.

The DGT's position remains constant in the application of the requirements of Law 19/1994, addressing specific aspects such as the residence of directors, investment in joint ownership, or the succession of workers. No changes in criteria are observed, but rather an application of the rule to different operational scenarios. The doctrine has become more precise regarding the nature of the activity and the calculation of staff and asset requirements.

Turning points

  1. V1345-21

    Specifies that the residence of at least one director must be in the Canary Islands, but does not require it to be on the same island as the registered office.

  2. V0294-22

    Allows for the counting of workers who transfer to the new company through business succession for the staff maintenance requirement.

  3. V0268-24

    Establishes the three requirements for intermediation to count towards the tax base: use of ICT, resources within the ZEC, and the absence of goods manipulation within the zone.

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

Rulings on this topic

8

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