The Inspection considers that 21% must be applied as it considers that it is a single service and the taxpayer understands that it is a question of two activities of different nature (parking and transport), to which the rate of 21% must be applied in the case of the parking of vehicles and the reduced rate of 10% in the case of the service of transfer of travelers to the airport or station. Subsidiarily, it considers the accessory nature of the parking service and that all the operations must be subsumed in the reduced rate corresponding to the main activity, which is, in its opinion, the transport activity. On the basis of the Community doctrine and the evidence in the file, it is concluded that the parking service is the main service with respect to the transport, which has the main activity, and that it is the main activity. The main activity in relation to the transport, which has the status of accessory, since the purpose pursued by the passengers is to be able to park their vehicle upon arrival at their destination. the purpose of the passengers is to be able to park their vehicle upon arrival at the port, airport or station concerned and until they return from their destinations. return from the corresponding destinations. The nature of the services provided, the circumstances in which the services are the circumstances in which the services are provided, the relative costs of both and the documentation collected by the administration and provided by the taxpayer and provided by the taxpayer show the ancillary nature of the transport to the airport. airport and therefore the application of the general rate to the totality of services rendered is confirmed.
Source: audiconsultores-etlglobal.com
