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V2373-23 5 September 2023 · SG de Impuestos sobre el Consumo Criterion in force
IVA · subvención vinculada al precio

Subsidies to promote employability must be included in the VAT taxable amount as price-linked subsidies

A cooperative has requested a ruling on whether a regional subsidy for job integration programmes should be taxed for VAT purposes as a price-linked subsidy. The DGT has ruled that it does constitute a price-linked subsidy, while also examining the possibility of an exemption based on social assistance.

The question raised

Whether the subsidy to be received by the applicant must form part of the Value Added Tax taxable base as a subsidy linked to the price.

The DGT's ruling

The subsidy constitutes the consideration for the services and, as it is a subsidy linked to the price, it must be included in the VAT taxable base. If the cooperative does not have the status of a private social establishment, the services shall be subject to the tax. In that case, the reduced rate of 10% shall apply if they are classified as social assistance, or the general rate of 21% in any other case.

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