How the DGT's position has evolved
Current position
Non-profit associations may carry out operations not exempt from IVA (Value Added Tax) in a manner compatible with their exemptions. The exemption for statutory membership fees applies only to services for members, excluding services to third parties or those with prices independent of the fee. For the social assistance exemption, the activity must be social assistance and the entity must be of a social nature.
The DGT's position remains stable regarding the distinction between exempt activities and economic activities. Consistency has been maintained in that income derived from economic exploitations or business activities is subject to tax. Recent rulings clarify the limits of the exemption in services to third parties and the management of the transfer of assets used for the activity.
Turning points
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Establishes that income from the transfer of an asset used for the activity does not enjoy an exemption if it is not reinvested in fixed assets. Determines that if the purpose constitutes an economic activity, the income will be subject to tax.
Analysis based on 35 of 37 rulings with a stated position. Updated 23 September 2026.