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V0903-23 18 April 2023 · SG de Impuestos sobre el Consumo Criterion in force
IVA · exención

The leasing or assignment of sports facilities to a football club is taxed at 21% VAT

A non-profit foundation inquires whether the leasing or the sale of a right of use of its sports facilities to a football club is exempt from VAT. The DGT responds that these operations are not exempt because their purpose is not the direct use by natural persons for sports practice, but rather the leasing of a fixed asset so that the club may carry out its activity.

The question raised

Question posed: Whether the exemption provided for in Article 20.One.13º of Law 37/1992 would be applicable to said operations.

The DGT's ruling

The leasing or the transfer of a right of use of sports facilities to a club is not considered directly related to the practice of sport by a natural person. These operations consist of the assignment of a fixed asset so that the club may carry out its habitual activity. Therefore, the exemption under Article 20.One.13º does not apply and they must be taxed at the general rate of 21%.

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