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V2193-23 26 July 2023 · SG de Impuestos sobre el Consumo Criterion in force
IVA · subvención vinculada al precio

Price-linked subsidies form part of the taxable base and must be included in the calculation of the deduction pro rata

A company performing both taxable and exempt VAT activities seeks clarification on whether a subsidy for technical assistance should be included in its pro rata calculation. The DGT rules that if the subsidy is linked to the price, it constitutes part of the taxable base and must be included in both the numerator and the denominator of the pro rata calculation.

The question raised

Impact of the receipt of the aforementioned subsidy on the calculation of the deduction pro rata.

The DGT's ruling

Subsidies directly linked to the price of transactions subject to tax form part of the taxable base. If the taxable person simultaneously carries out taxable and exempt transactions, the pro rata rule must be applied. In this calculation, transactions financed with subsidies linked to the price must be included in both the numerator and the denominator of the pro rata fraction.

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