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V2880-23 25 October 2023 · SG de Impuestos sobre el Consumo Criterion in force
IVA · servicio único

The organization of sporting events is not subject to VAT if the recipient is a non-resident professional

An entity organizes football 'clinics' for teams and academies established outside of Spain. The DGT determines that the organization of these events constitutes a single service and that, if the client is a business person without a registered office in Spain, the transaction is not carried out in Spanish territory.

The question raised

Question posed: Whether the organization of the consulted 'clinics' is subject to Value Added Tax.

The DGT's ruling

The organization of sporting events is a single service composed of a plurality of closely linked elements. If the recipient is a business person or professional who does not have their registered office, permanent establishment, or domicile in Spain, the provision is not understood to be carried out in Spanish territory. In this case, the organizing entity must not charge VAT. If the recipient is not a business person, the service is understood to be carried out in Spain if it is materially provided within this territory.

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