How the DGT's position has evolved
Current position
The exemption requires meeting both a subjective and an objective requirement. The subjective requirement demands that the activity be carried out by public law entities or authorized private law entities whose primary purpose is teaching included in a recognized curriculum. The objective requirement demands the transmission of knowledge and skills within an organizational framework, without being merely recreational or for the satisfaction of personal needs.
The DGT's position has remained constant since 2014, reiterating the need for both subjective and objective requirements to coexist. No changes have been observed in the interpretation of what constitutes an authorized entity or the nature of the activity. The doctrine has remained stable throughout all the analyzed rulings.
Analysis based on 62 of 65 rulings with a stated position. Updated 23 September 2026.