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V0406-18 16 February 2018 · SG de Impuestos sobre el Consumo Criterion in force
IVA · exención

VAT should not be applied to international air transport services with a hub stopover via a single transport document

An airline has requested a ruling on whether international journeys requiring a stopover at a domestic airport under a single ticket are VAT exempt. The DGT has determined that, as this constitutes a single transport operation, the exemption under Article 22.Thirteen of the VAT Act applies.

The question raised

Application of the exemption contained in Article 22.Thirteen of Law 37/1992 to the aforementioned transport service.

The DGT's ruling

Air transport services with origin or destination outside the national territory that require a connection at a national 'hub' airport through a single transport document constitute a single supply. When analyzed as a single operation rather than separate supplies, the exemption provided in Article 22.Thirteen of Law 37/1992 applies. To determine this unity, factors such as a single price, contracting from origin to final destination, and passenger compensation regulations are considered.

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