Doctrine by topic · DGT Observatory

Collaboration Agreements: 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 14 rulings · 2014–2026

Current position

Business collaboration agreements for activities of general interest under Law 49/2002 do not constitute a provision of services and are not subject to IVA (Value Added Tax). Advertising sponsorship, on the other hand, is a provision of services subject to the tax. The dissemination of the collaborator's participation within the framework of said agreements is not considered a service subject to IVA.

The DGT's position remains constant regarding the distinction between advertising sponsorship and Law 49/2002 agreements. Throughout the rulings, it has been reaffirmed that business collaboration under this regime is not an operation subject to IVA, whereas sponsorship is. The most recent rulings specify the possible coexistence of independent provisions in sponsorship programs.

Turning points

  1. V2199-18

    Clarifies the technical distinction by stating that the dissemination of the collaborator's participation in Law 49/2002 agreements does not constitute a provision of services.

  2. V5123-26

    Introduces the possibility that sponsorship programs may involve two independent provisions: dissemination and access to events.

Analysis based on 14 of 14 rulings with a stated position. Updated 26 September 2026.

Rulings on this topic

14
V5123-26 7 Jul 2026

Foundation activities may be subject to VAT depending on their nature

SG de Impuestos sobre el Consumo
patrocinioconvenio de colaboraciónestablecimiento de carácter socialprestación de serviciosexención LIVA — Ley 37/1992 del IVA art. 4.1LIVA — Ley 37/1992 del IVA art. 5.1
Affects CompanyExpat · Non-residentIndividual

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