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Directly Necessary Services: 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 9 rulings · 2015–2022

Current position

The exemption under Article 20.One.6º of the IVA (Value Added Tax) Law requires that services provided by an association to its members be directly necessary for the exercise of their exempt activity. It does not apply to services of a general nature such as cleaning, security, tax advisory, auditing, or human resources. The rule does not seek to benefit the outsourcing of services or corporate restructuring.

The DGT's position has remained constant over time, rejecting the exemption for services of a general nature. Throughout various rulings, the criterion has been maintained that the exemption must not favor the outsourcing of activities. Only additional examples of excluded services have been provided, such as technical assistance to patients or the reimbursement of common expenses.

Turning points

  1. V2534-19

    Introduces the possibility that patient assistance services provided by auxiliary technicians may indeed be considered directly necessary for medical activity.

  2. V0378-21

    Specifies that the exemption applies as long as the services are limited to the reimbursement of common expenses.

Analysis based on 8 of 9 rulings with a stated position. Updated 29 September 2026.

Rulings on this topic

9

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