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Therapeutic Purpose: 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 59 rulings · 2014–2026

Current position

The VAT exemption requires meeting an objective requirement (services for the diagnosis, prevention, or treatment of diseases) and a subjective one (provided by medical or healthcare professionals). Aesthetic interventions are exempt only if they derive from a disease, injury, or congenital physical defect. Services with purely cosmetic, physical maintenance, relaxing, or weight loss purposes without a medical basis are not included.

The DGT's position has remained constant since 2014, always applying the requirements of therapeutic purpose and professional qualification. The evolution is limited to the application of the criterion to new typologies of services, such as DNA analysis, dietitian services, or chiropractic care, without altering the base doctrine.

Turning points

  1. V2321-17

    Extends the exemption to DNA analysis services to identify food intolerances by considering them diagnostic for subsequent treatment.

  2. V0401-21

    Specifies that if the primary purpose is to facilitate an opinion so that a third party can make a decision with legal effects, the service is subject to the general rate.

  3. V5417-26

    Clarifies that chiropractic services are exempt if the professional possesses the necessary qualifications, even without being a regulated profession.

Analysis based on 57 of 59 rulings with a stated position. Updated 23 September 2026.

Rulings on this topic

24
V0781-23 3 Apr 2023

Physiotherapy deemed a professional activity; VAT exemption depends on service purpose

SG de Impuestos sobre la Renta de las Personas Físicas
rendimientos de actividades profesionalesobligación de retenerexención de asistencia sanitariafinalidad terapéuticaactividades económicas RIRPF — RD 439/2007, Reglamento del IRPF art. 74RIRPF — RD 439/2007, Reglamento del IRPF art. 75.1
Affects CompanyExpat · Non-residentIndividual

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