How the DGT's position has evolved
Current position
Contributions from Public Administrations to finance public services are not considered subsidies linked to the price, nor do they form part of the consideration for operations subject to VAT if there is no significant distortion of competition. In services such as urban, interurban, or school transport, these contributions do not form part of the taxable base. However, amounts paid by users for non-mandatory services do constitute consideration subject to VAT.
The DGT's position has remained constant since 2017. The criterion establishes that the absence of significant distortion of competition prevents public contributions from being considered linked to the price. The most recent rulings maintain this logic applied to new scenarios such as school transport or compensations for price reductions.
Turning points
-
Introduces the distinction in school transport, clarifying that amounts paid by students for non-mandatory transport do constitute consideration subject to VAT at 10%.
Analysis based on 66 of 71 rulings with a stated position. Updated 21 September 2026.