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V2888-23 26 October 2023 · SG de Impuestos sobre el Consumo Criterion in force
IVA · bono polivalente

Gym bonds deemed polyvalent for VAT across countries

A foreign platform asks whether its monthly gym and health service vouchers are polyvalent. The DGT confirms they are, as the exact tax treatment of such services was unknown at issuance.

The question raised

Whether such bonds are considered multipurpose bonds for Value Added Tax purposes and the taxable base of the underlying services.

The DGT's ruling

Bonds are multipurpose as the taxation of the underlying services is unknown at the time of their issuance, especially if they can be performed in different territories or tax rates. The transfer of the bond by the issuer is not subject to VAT if the issuer is not established in Spain. The taxable base of the underlying services shall be the amount of the bond minus the VAT amount, and a reasonable criterion must be applied to individualize the amount for each use or validation.

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