Doctrine by topic · DGT Observatory

Authorized Private Entity: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

← DGT Observatory

How the DGT's position has evolved

Settled doctrine High confidence 40 rulings · 2014–2024

Current position

The exemption for educational services requires a subjective requirement, that the entity be of public law or an authorized private law entity, and an objective requirement, that the activity transmits knowledge and skills without being merely recreational. The subjects taught must be included in a curriculum of the educational system. Services provided electronically with ancillary human intervention do not benefit from the exemption and are taxed at the general rate.

The DGT's position remains constant in requiring subjective and objective requirements for the exemption. The evolution shows technical precision regarding the nature of the activity, distinguishing between real teaching and services provided electronically or for recreational purposes. There are no fundamental changes, but rather a delimitation of the cases that do not meet the exemption requirements.

Turning points

  1. V1863-16

    Introduces the distinction that automated distance learning with ancillary human intervention is a service provided electronically, excluding it from the exemption.

  2. V1005-20

    Reiterates and confirms that the supply of recorded or automated content through platforms does not allow for the exemption, as it is classified as electronically supplied services.

Analysis based on 38 of 40 rulings with a stated position. Updated 23 September 2026.

Rulings on this topic

24

Apply this to your case

VAT advisoryTalk to the team applying this doctrine daily.
Talk to the tax teamWe check whether this criterion affects you and what it means in your situation.
Email
Contact