If the services are rendered by different subjects, an accessory relationship cannot be considered. The “secondary” services cannot be qualified as ancillary to the “main” one if they are not rendered directly by the person who performs the latter or on his behalf or at his expense This is what was reiterated by the Revenue Agency in its response to ruling no. 520 published yesterday, October 19, 2022. In the event that the secondary services are not rendered directly by the person who performs them, or on his behalf or at his expense, they cannot be qualified as ancillary to the main one .
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