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Passenger Transport: 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 10 rulings · 2014–2024

Current position

Passenger transport is considered to be carried out in national territory for the portion of the journey that traverses it, applying the reduced rate of 10%. If the service originates or is destined outside the scope of the tax, the operation is taxable but exempt. In the case of boat rental without a crew, the travel agency regime does not apply as it is treated as a lease of goods.

The DGT's position remains constant in determining the location of transport based on the portion of the journey traveled. Total exemption has been consolidated for services with an origin or destination outside national territory, including flights with layovers in national hubs. Recent doctrine specifies the distinction between transport services and leases of goods without a crew.

Turning points

  1. V2813-19

    Establishes that flights with layovers in national airports are exempt if the origin or final destination is a third country, applying the exemption to the entire operation.

  2. V0109-24

    Clarifies that the rental of a boat without a crew does not constitute a transport service, but rather a lease of goods, excluding the application of the special travel agency regime.

Analysis based on 9 of 10 rulings with a stated position. Updated 28 September 2026.

Rulings on this topic

10

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