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Professional Training and Retraining: 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 28 rulings · 2014–2026

Current position

The exemption under Article 20.One.9º of Law 37/1992 requires a subjective requirement, that the entity be a public or private law entity authorized for teaching, and an objective requirement, that the activity consists of the transmission of knowledge and skills without a recreational character. The subjects must be included in the curricula of the educational system. The exemption does not apply if the service is ancillary to the sale or lease of goods or computer programs.

The DGT's position remains constant regarding the requirement of both subjective and objective criteria. Throughout the rulings, the necessity for the subjects to be part of official curricula has been maintained. The only evolution is the clarification regarding the impropriety of the exemption when training is ancillary to the delivery of software or machinery.

Turning points

  1. V1351-20

    Introduces the exclusion of the exemption when training services are ancillary to the sale or lease of machines or computer programs.

Analysis based on 27 of 28 rulings with a stated position. Updated 24 September 2026.

Rulings on this topic

24
V0804-26 10 Apr 2026

Aquatic rescue and first aid training courses exempt from VAT

SG de Impuestos sobre el Consumo
exenciónformación y reciclaje profesionalentidad autorizadaplan de estudiossocorrismo acuático 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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