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V1463-15 11 May 2015 · SG de Impuestos sobre el Consumo Criterion in force
IVA · prestación de servicios

Passenger transport services are subject to VAT for the portion of the journey occurring within Spain

A bus company inquires regarding the taxation of its passenger transport services between Spain and France to clients of various nationalities. The DGT responds that the service is subject to VAT for the portion of the journey occurring within Spanish territory.

The question raised

Question posed: Taxation of the transport services performed.

The DGT's ruling

The transport activity is a provision of services subject to Tax. The location of these services is determined by the portion of the journey occurring within the territory to which the Tax applies. To determine the location, the nationality or nature of the recipients, whether they are entrepreneurs or final consumers, is irrelevant.

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