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V2134-22 11 October 2022 · SG de Impuestos sobre el Consumo Criterion in force
IVA · entrega de bienes

Sale of aircraft for export and related training may be exempt from VAT

A French company has requested a ruling regarding the taxation of aircraft sales for export, including training services and conversion into military tankers. The DGT has determined that the supply of goods and the training constitute a single operation and that the export may be exempt.

The question raised

Taxation of the following operations described for the purposes of Value Added Tax and, specifically: sale of aircraft for export together with the training necessary to ensure their airworthiness by the applicant and training and conversion services into military tankers provided by the Spanish subsidiary of the group.

The DGT's ruling

The training service is ancillary to the delivery of the aircraft, and therefore follows the same tax regime as the delivery. The delivery of goods for export is exempt if the requirements of the Regulation are met, even if the departure occurs after the regulatory deadlines, provided that the intention to export is proven. The training services provided to the French subsidiary and the conversion services invoiced to the non-established purchaser are not subject to tax.

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