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Transfer of Knowledge: 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 46 rulings · 2014–2024

Current position

The exemption under Article 20.One.9º of Law 37/1992 requires compliance with both a subjective and an objective requirement. The subjective requirement necessitates that the entity be a public or authorized private law entity, understanding 'authorized' to mean one whose activity is primarily teaching included in a recognized curriculum. The objective requirement necessitates the transfer of knowledge and skills within an organizational framework and without a merely recreational character.

The DGT's position has remained constant since 2014, always applying the same subjective and objective requirements. No changes have been observed in the interpretation of the exemption, maintaining the necessity for the subject matter to be part of a recognized curriculum to avoid a recreational character.

Turning points

  1. V2169-17

    Distinguishes between acting as a professional and as a company, specifying that if acting as a professional, classes must be taught by natural persons and the subject matter must be included in official curricula.

Analysis based on 45 of 46 rulings with a stated position. Updated 23 September 2026.

Rulings on this topic

24
V0661-17 15 Mar 2017

Dance teaching may be VAT exempt if it is not merely recreational

SG de Impuestos sobre el Consumo
exención de enseñanzaentidades autorizadascarácter recreativotransmisión de conocimientosplan de estudios LIVA — Ley 37/1992 del IVA art. 4.unoLIVA — Ley 37/1992 del IVA art. 20.uno.9º
Affects CompanyExpat · Non-residentIndividual

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