How the DGT's position has evolved
Current position
The VAT exemption for training services requires that the subjects taught be included in a curriculum of the educational system, as determined by the Ministry of Education or the autonomous community. This condition is maintained even if the training is eminently practical or takes place in clinical facilities. If the exemption is applied, there is no right to deduct the input VAT incurred.
The DGT's position on the status of a public law entity and its tax benefits does not show a coherent doctrinal evolution in the sequence, as the rulings concern different matters (Corporate Income Tax, Treaties, VAT, and COVID-19 measures). There is no common thread that allows for the establishment of a change in criterion regarding the definition of a public law entity.
Analysis based on 49 of 51 rulings with a stated position. Updated 23 September 2026.