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V2241-19 20 August 2019 · SG de Impuestos sobre el Consumo Criterion in force
IVA · derechos de imagen

Professional athlete services subject to VAT based on destination rules

A professional athlete enquires about VAT applicability on income from sponsorship, image rights, prizes and scholarships, and the deductibility of expenses. The DGT determines VAT applicability based on the recipient or event location, clarifying that public scholarships are generally exempt.

The question raised

Liability for Value Added Tax and, where applicable, the taxable person and the applicable tax rate for these operations.

The DGT's ruling

Sponsorship services and the assignment of image rights are subject to VAT when the recipient is an entrepreneur or professional with a registered office or establishment in Spain. Prizes for sporting competitions are subject to tax if the recipient is a professional or if the competition is materially held in Spain. Scholarships from public entities for general interest do not constitute a service subject to tax. The applicable tax rate is the general rate of 21%.

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