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V1350-18 23 May 2018 · SG de Impuestos sobre el Consumo Criterion in force
IVA · base imponible

Subsidies to cover the operating deficit of a concessioned public service are included in the VAT taxable base

A city council inquires whether the subsidy to cover the deficit of a sports complex managed by a company is part of the VAT taxable base. The DGT responds that, as it is a contribution to guarantee the continuity of the service when tariffs are insufficient, it constitutes consideration and is subject to the tax.

The question raised

Question raised: Subjectivity to Value Added Tax of the aforementioned subsidies.

The DGT's ruling

Subsidies that constitute the total or partial consideration for a service operation are included in the VAT taxable base. For a subsidy to be considered linked to the price, there must be a direct link between the service provided and the amounts received. In this case, the contribution to cover the operating deficit is considered part of the consideration for the services provided.

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