EU
- VAT – Commission takes steps against Spain regarding
its rules to determine the taxable amount of VAT in case
of barter transactions
Certain
rules applied in Spain to ascertain the taxable amount
of VAT for barter transactions (in particular, where the
transaction involves the acquisition of a future
building) are, in the opinion of the Commission, in
breach of Community Law.
In
Spain, when a future building or part thereof is sold and paid
for prior to its final construction, VAT is charged at the
time the payment is made, and the taxable amount is the amount
actually paid. No additional VAT is levied at a later stage
when, upon final construction, the building is delivered to
the purchaser. This is in conformity with the VAT Directive.
However,
in the same situation, if the advance payment of the planned
building is made in kind (for example, if the purchaser of the
planned building pays by supplying a piece of real state) the
taxable amount for the purposes of VAT is different. In that
case:
VAT
is levied when the advance payment is made on the basis of
the market value foreseen for the building once it has
been constructed;
if,
once construction is over, the market value of the
building is higher than foreseen, a correction of the
taxable amount initially calculated must be made and the
purchaser of the building is requested to pay VAT on the
difference.
The
Commission understands that the product supplied is identical
in both transactions and that only the means of payment are
different. According to the European Court of Justice, using
different means of payment for acquiring a product cannot lead
to a different VAT liability.
For
these reasons, the Commission has formally requested Spain to
change its administrative practice by means of a reasoned
opinion.