Doctrine by topic · DGT Observatory

Educational 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 8 rulings · 2015–2025

Current position

The exemption for educational services requires meeting a subjective requirement (authorized entity) and an objective one (transmission of non-recreational knowledge included in curricula). If the service is provided by electronic means (automated and with minimal human intervention), the rules of localization according to the recipient apply. On digital platforms, the presumption of acting on one's own behalf is established if the entity authorizes the charge or sets the general conditions.

The DGT's position remains stable regarding the requirements for the educational exemption (authorized entity and non-recreational content). The evolution focuses on the technical distinction between educational services and services provided by electronic means to determine localization and the taxable person. The nature of online training and the role of digital platforms in determining taxation has been clarified.

Turning points

  1. V0389-21

    Defines that online training services are services provided by electronic means if they are automated and require little human intervention, which prevents their exemption.

  2. V2630-24

    Establishes the presumption that the platform acts on its own behalf if it authorizes the charge to the customer or sets the general conditions.

Analysis based on 8 of 8 rulings with a stated position. Updated 13 October 2026.

Rulings on this topic

8
V5141-16 28 Nov 2016

Drone pilot training may be VAT exempt if classified as vocational training

SG de Impuestos sobre el Consumo
exención de enseñanzaformación profesionalservicios prestados por vía electrónicatítulos aeronáuticosactividad profesional LIVA — Ley 37/1992 del IVA art. 20.Uno.9ºLIVA — Ley 37/1992 del IVA art. 5
Affects CompanyExpat · Non-residentIndividual

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