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An academy has enquired whether a subsidy intended to finance its training activities constitutes a price-linked subsidy and how this affects its right to VAT deduction. The DGT has ruled that if a direct link exists between the subsidy and the service, it forms part of the consideration and will receive the same tax treatment as the service provided.
Question raised: Whether the subsidy is linked to the price and whether it entails any limitation on the right to deduction in accordance with the Value Added Tax Act.
Subsidies directly linked to the price, determined by the number of units or volume of services, are included in the taxable base. If there is a direct link between the consideration and the service, the subsidy is considered part of the consideration. If the service is exempt, the subsidy shall also be exempt. For VAT deduction purposes, the split method or the pro rata rule shall apply according to the nature of the activities.
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