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Authorized Entity: 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 110 rulings · 2014–2026

Current position

The exemption under Article 20.One.9º requires meeting a subjective requirement, that the entity is authorized for teaching, and an objective one, that the activity consists of the transmission of knowledge and skills without a recreational character. Furthermore, the subjects must be included in some curriculum of the educational system. If the service is automated or through recorded content with minimal human intervention, it is considered a service provided by electronic means and is taxed at 21% IVA (Value Added Tax).

The DGT's position remains constant in requiring the double condition of being an authorized entity and subjects being integrated into curricula. The distinction between educational services and services provided by electronic means has been reinforced, determining that the automation of content shifts the exemption toward the general rate of 21%.

Turning points

  1. V3438-20

    Establishes that the supply of downloadable files and videos constitutes a service provided by electronic means that is taxed at 21%, excluding the educational exemption.

Analysis based on 106 of 110 rulings with a stated position. Updated 21 September 2026.

Rulings on this topic

24
V0778-26 8 Apr 2026

Online training with pre-recorded content liable to 21% VAT

SG de Impuestos sobre el Consumo
servicio prestado por vía electrónicaexención de servicios educativosinteracción humanaenseñanza a distanciasujeción al impuesto LIVA — Ley 37/1992 del IVA art. 4.unoLIVA — Ley 37/1992 del IVA art. 5.uno
Affects CompanyExpat · Non-residentIndividual

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