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V3219-16 11 July 2016 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · cheques regalo

Issuance of gift vouchers by an association is subject to but exempt from VAT and may be exempt from CIT

A trade association has requested clarification regarding the tax implications of issuing gift vouchers redeemable at its member establishments. The DGT has determined that the issuance of these vouchers is subject to but exempt from VAT as they constitute a means of payment, and that the association's income will be exempt from CIT provided it does not derive from an economic activity.

The question raised

1) What would be the consequences of this type of operation for the purposes of Corporate Income Tax and Value Added Tax.

The DGT's ruling

Regarding VAT, the issuance and delivery of gift vouchers constitutes a taxable operation but is exempt as it is considered a means of payment under the concept of "other commercial effects". Regarding Corporate Income Tax, the association's income shall be exempt if it arises from its specific purpose and does not constitute an economic activity. If an economic activity is carried out, the income derived from it shall be subject to tax.

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