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V3252-15 23 October 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · entidad parcialmente exenta

Student exchange grants: non-deductible for CIT, exempt from VAT and taxable for IRPF

A non-profit association has requested a ruling on the tax treatment of grants for student and teacher exchanges. The DGT has determined that these grants are not deductible for Corporate Income Tax, are not subject to VAT, and constitute employment income for the beneficiaries.

The question raised

Question posed: What would be the tax treatment of these grants by the non-profit association and by the beneficiaries thereof.

The DGT's ruling

The grants are not deductible for Corporate Income Tax as they are considered donations or gratuities without consideration. They are not subject to VAT as there is no legal relationship of exchange of benefits between the association and the universities. For the beneficiaries, these grants are employment income subject to taxation under Personal Income Tax, and the association must apply the corresponding withholding tax.

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