How the DGT's position has evolved
Current position
Contributions from Public Administrations for mandatory school transport do not constitute consideration or subsidies linked to the price, and therefore are not subject to IVA (Value Added Tax). Non-mandatory school transport constitutes a service subject to the tax at the reduced rate of 10%. In the case of mandatory transport, providers must rectify any unduly charged tax amounts.
The position has evolved from determining the applicable tax rate for transport services (10%) towards a technical distinction between mandatory and non-mandatory transport. The DGT has clarified that public contributions for mandatory transport are not operations subject to IVA as there is no distortion of competition. This necessitates the rectification of tax amounts in mandatory services where the tax was erroneously applied.
Turning points
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Establishes that school transport services, although not exempt, are taxed at the reduced rate of 10% as they are child protection services.
Analysis based on 17 of 17 rulings with a stated position. Updated 25 September 2026.