How the DGT's position has evolved
Current position
Consideration requires an onerous and continuous activity that involves assuming risk and venture. Contributions from Public Administrations for school transport are neither consideration nor subsidies linked to the price if they do not distort competition. Amounts paid by users in non-mandatory transport do constitute consideration subject to VAT with a reduced rate. Compensations for waste management are considered consideration for a service subject to VAT at 10%.
The DGT has moved from treating consideration in the context of VAT model information (2016) to defining its nature in complex scenarios involving subsidies and public services. The distinction between public contributions without distortion of competition and user payments that do constitute consideration has been consolidated. Current doctrine requires the existence of a direct relationship with the price for a subsidy to be included in the taxable base.
Turning points
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Establishes that contributions for school transport are neither consideration nor subsidies linked to the price as there is no distortion of competition.
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Determines that compensations for waste management are consideration for a service provided on an onerous basis and are not of a tax nature.
Analysis based on 80 of 81 rulings with a stated position. Updated 6 September 2026.