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Educational Center: 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 8 rulings · 2014–2021

Current position

The exemption under article 20.one.9º of the IVA (Value Added Tax) Law applies to teaching services and support or supervision activities in educational centers, provided they are linked to enrolled students and contents of the educational system. It does not extend to transport services, excursions or camps, nor to sports practices provided by entities other than the educational centers. The exemption requires that the activity be teaching-related and included in an official curriculum.

The DGT's position remains constant regarding the application of the exemption to support and supervision services during after-school hours. The doctrine has progressively specified the limits of the exemption, especially in sports and certification activities, conditioning the benefit on the student's enrollment in the center or the inclusion of the contents in official curricula.

Turning points

  1. V2328-17

    The exemption for care, support, and supervision services during after-school hours is confirmed, regardless of whether it is invoiced to the center or to the parents.

  2. V2690-21

    It is established that the exemption for quality certification services depends on the evaluated courses belonging to the curricula of the Spanish educational system.

  3. V2830-21

    It is delimited that the exemption requires the activity to be teaching-related and included in an official curriculum, excluding sports practice if it does not meet this requirement.

Analysis based on 6 of 8 rulings with a stated position. Updated 1 October 2026.

Rulings on this topic

8
V2328-17 14 Sept 2017

Morning nursery services in schools are exempt from VAT

SG de Impuestos sobre el Consumo
exención educativaguarda y custodiahorario extraescolarcentro docenteprestación de servicios LIVA — Ley 37/1992 del IVA art. 4.1LIVA — Ley 37/1992 del IVA art. 20.1.9º
Affects CompanyExpat · Non-residentIndividual

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