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V2345-18 20 August 2018 · SG de Impuestos sobre el Consumo Criterion in force
IVA · programa de fidelización

Management services for a loyalty points programme are subject to VAT

An association has requested a ruling regarding the VAT liability of fixed fees and the purchase/redemption of points within a loyalty programme. The Directorate General for Taxes (DGT) has ruled that these amounts constitute consideration for promotional services subject to the tax.

The question raised

Liability for Value Added Tax regarding the aforementioned fixed fee to be received by the taxpayer, as well as the deliveries and returns of points carried out by the taxpayer and the establishments, respectively.

The DGT's ruling

The management of a loyalty system constitutes a promotional service subject to and not exempt from VAT. The fixed fee and the variable amount for points acquired by the establishments are the consideration for said services. In the event of a return of points by the establishments, a corrective invoice must be issued to modify the taxable base.

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