Doctrine by topic · DGT Observatory

Symbolic Consideration: DGT doctrinal evolution

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

← DGT Observatory

How the DGT's position has evolved

Settled doctrine High confidence 9 rulings · 2014–2023

Current position

The status of a taxable person for VAT (IVA) purposes requires performing activities for consideration. If the consideration is merely symbolic or disproportionately lower than the market value, the transaction is considered to be without consideration and the entity does not hold the status of a taxable person. Donations, contributions, and subsidies do not constitute consideration for a supply of goods or services.

The DGT's position has remained constant since 2014. The criterion establishes that the existence of real consideration, which is neither symbolic nor disproportionate, is the determining element for a non-profit entity to acquire the status of a taxable person. The rulings maintain the same logic regarding the lack of liability when the price is symbolic.

Analysis based on 9 of 9 rulings with a stated position. Updated 29 September 2026.

Rulings on this topic

9

Apply this to your case

VAT advisoryTalk to the team applying this doctrine daily.
Talk to the tax teamWe check whether this criterion affects you and what it means in your situation.
Email
Contact