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A non-profit private healthcare centre sought clarification on whether the total financial contribution from its Autonomous Community to cover healthcare service costs was subject to VAT and whether it should be included in the volume of operations for the Immediate Supply of Information system (SII). The DGT ruled that such a contribution constitutes consideration for healthcare and hospitalisation services, and is therefore subject to VAT, even if it may be exempt.
Question raised: Whether said contribution would be subject to Value Added Tax and whether it should be included in the calculation of the taxpayer's volume of operations for the purposes of the Immediate Information System (SII).
The economic contribution made by the Administration to cover fixed and variable costs of the healthcare activity constitutes the consideration for the provision of hospitalization and healthcare services. As it is a consideration, the transaction is subject to VAT, without prejudice to the possible application of the exemption under Article 20.one.2º and 3º of Law 37/1992. Likewise, these amounts must be included in the calculation of the volume of operations for the SII, even if the services are exempt.
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