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Practical Handbook VAT 2022


  1. The following persons are jointly and severally liable for the payment of the tax debt:

    1. The recipients of transactions who, by culpable or fraudulent act or omission, evade the correct charging of the tax.The liability shall extend to the sanction that may be applicable.

    2. In case of imports of goods:

      • The guarantor associations in the cases determined in the International Conventions.

      • The RENFE, when acting on behalf of third parties by virtue of International Agreements.

      • Persons or entities acting in their own name and on behalf of importers.

  2. The subsidiary liability is established for the payment of the tax debt of the following persons:

    1. Customs agents acting in the name and on behalf of their principals.

    2. Entrepreneurs or professionals who are recipients of transactions in respect of which they should reasonably presume that the output tax charged or which should have been charged has not been or will not be collected.

      This is considered to be the case when a notoriously abnormal price has been paid.

      A notoriously abnormal price is defined as a notoriously abnormal price:

      • That which is significantly lower than that corresponding to such goods under the conditions in which the transaction was carried out or that which was paid in previous acquisitions of identical goods.

      • If it is significantly lower than the purchase price of the goods by the supplier.

      A price which is justified by the existence of economic factors other than the application of the tax shall not be considered a manifestly abnormal price .

      In addition to a finding that a grossly anomalous price has been paid, a further requirement for a finding of this type of liability is also necessary:

      The tax authorities must prove the existence of a tax charged or which should have been charged but which has not been declared and paid.

    3. The holders of warehouses other than customs warehouses are liable for the payment of the tax debt corresponding to the removal or abandonment of goods from these warehouses.