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Profit Motive: 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 48 rulings · 2014–2026

Current position

To apply the exemption under Article 20.One.13º, services must be directly related to the practice of sport or physical education by a natural person. The entity must be of a social nature, lacking a profit motive, with free charges, and without the members being the primary beneficiaries under special conditions. The exemption is applicable regardless of whether the entity has obtained a formal qualification before the AEAT.

The DGT's position remains constant in the definition of a social entity, requiring the absence of a profit motive, free charges, and that members are not the primary beneficiaries. Throughout the rulings, it has been specified that the exemption does not extend to the delivery of goods or to services that satisfy the particular interests of members. The doctrine confirms that the nature of the entity is determined by its facts and not by a formal qualification.

Turning points

  1. V4119-15

    Establishes that a commercial company may meet the social nature requirement if it does not seek systematic profits and allocates surpluses to the maintenance of its services.

  2. V2495-19

    Specifies that the exemption does not apply when the consideration seeks to satisfy a particular or individual interest of the member, as occurs with fees for inclusion in lists.

Analysis based on 46 of 48 rulings with a stated position. Updated 23 September 2026.

Rulings on this topic

24
V1213-20 4 May 2020

Sports services provided by social entities may be exempt from VAT

SG de Impuestos sobre el Consumo
exenciónestablecimiento de carácter socialprestación de serviciosfinalidad lucrativaactividad deportiva 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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