mr. J. el Khalfioui LL.M.

, in VAT

Football tickets for clients: Spain may keep its block on VAT deduction

On 12 March 2026, the Court of Justice ruled in Randstad España (C-515/24) that Spain's exclusion of VAT deduction on gifts and entertainment for clients is compatible with the VAT Directive.

The case

In 2009 to 2011, Randstad España bought tickets for football matches of Real Madrid and FC Barcelona, invitations to the Paddock Club at the Formula 1 Grand Prix of Spain and invitations to trips on board a ship, and gave them to its clients for free. It deducted the VAT. The Spanish tax authority refused, and relied on the standstill clause in the second paragraph of Article 176 of the VAT Directive.

Under that clause, Member States may keep exclusions from deduction that their law provided for at the time of accession. Randstad argued that the Spanish rule did not qualify, because it was not in force before accession. Spain had no comparable VAT system before it joined on 1 January 1986.

The ruling

The clause does not preclude a national rule that enters into force on the date of accession and excludes deduction on such spending. The Court pointed out three things:

The Court also noted that it does not matter that the same costs are deductible for income tax. That tax is not harmonised and has other aims.

What to check

mr. J. el Khalfioui LL.M.

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