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V0454-25 25 March 2025 · SG de Impuestos sobre el Consumo Criterion in force
IVA · cesión de alumnos

Student transfers between driving schools are subject to 21% VAT, not exempt from training VAT

A body collaborating with driving schools asks whether student transfers are exempt from VAT as a training activity. The DGT responds that student transfers constitute an independent service provision and are therefore subject to the standard VAT rate.

The question raised

Question posed: Whether the transfer of students could be exempt from Value Added Tax, given that it is related to driving training activities which are exempt from Tax pursuant to Article 20 of Law 37/1992 on Value Added Tax.

The DGT's ruling

The transfer of students between driving schools constitutes a provision of services independent of training services. Therefore, the exemption provided in Article 20.one.9º of Law 37/1992 is not applicable. This transaction is subject to VAT at the general rate of 21 percent.

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