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Recreational Character: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 58 rulings · 2014–2024

Current position

The exemption under article 20.one.9º of Law 37/1992 requires a subjective requirement, that the entity be authorized for teaching, and an objective requirement, that the activity transmits knowledge and skills without a merely recreational character. Furthermore, the subject must be included in the curricula of the Spanish educational system. The recreational character is determined by the nature of the activity and its integration into a teaching organizational framework.

The DGT's position has remained constant since 2014, always applying the duality of subjective and objective requirements. No changes have been observed in the interpretation of the exemption, maintaining the requirement that the subject forms part of the official curricula to avoid a merely recreational character.

Analysis based on 54 of 58 rulings with a stated position. Updated 23 September 2026.

Rulings on this topic

24
V0661-17 15 Mar 2017

Dance teaching may be VAT exempt if it is not merely recreational

SG de Impuestos sobre el Consumo
exención de enseñanzaentidades autorizadascarácter recreativotransmisión de conocimientosplan de estudios LIVA — Ley 37/1992 del IVA art. 4.unoLIVA — Ley 37/1992 del IVA art. 20.uno.9º
Affects CompanyExpat · Non-residentIndividual

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