The Directorate General for Legal Certainty and Public Faith has ruled that a registrar's negative assessment, which prevented assigning a short-term rental registration number to a commercial premises, is improper. Although Royal Decree 1312/2024 refers to dwellings, if a premises is adapted for temporary residential use and holds the relevant planning and activity licences, it must comply with the same transparency and control obligations as a dwelling (Art. 4). The resolution prevents the registered status of 'commercial premises' from being an obstacle if the functional and administrative reality is that of tourist accommodation.
For owners of commercial premises intending to convert them into tourist accommodation, the resolution provides a pathway to obtain a single registration number, provided they hold the necessary local authority activity and operating licences and are registered in the regional register (Art. 4). This prevents registration as 'commercial premises' from blocking tourist activity if the property meets the equipment and temporary use requirements set out by Regulation (EU) 2024/1028 and Law 29/1994.
The tax team reviews your specific situation.