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A PTA has enquired whether the transfer of funds from a local authority to finance an educational activity is subject to VAT. The DGT has ruled that, as there is no legal relationship involving the exchange of reciprocal benefits, the funds do not constitute consideration for a service.
Question raised: Taxation under Value Added Tax. Type of document to be issued by the PTA.
Parent and Teacher Associations do not possess a business nature by virtue of their membership fees, unless they carry out habitual economic activities for consideration. The transfer of funds from a city council to cover the expenses of an activity does not constitute consideration for a service, as there is no direct link where the remuneration is the countervalue of a provision. In the absence of an act of consumption or a concrete benefit for the city council, the operation falls outside the scope of VAT.
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