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V0235-20 4 February 2020 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IVA · afectación a la actividad

Mixed-use vehicles not used for goods transport do not benefit from full tax attribution presumption

A self-employed person asks whether they can deduct 100% of VAT and IRPF on a mixed-use vehicle purchased for their business. The DGT responds that, since the vehicle is not used for transporting goods, the full attribution presumption does not apply and professional use must be proven.

The question raised

Deduction of both VAT and Personal Income Tax for a new vehicle used 100% for business purposes.

The DGT's ruling

Regarding VAT, mixed-use vehicles are only presumed to be 100% business-related if they are effectively used for the transport of goods; otherwise, a 50% presumption applies. The taxpayer may prove a different degree, but the tax return or accounting records alone are insufficient. Regarding Personal Income Tax (IRPF), to deduct vehicle expenses, the vehicle must be an asset used for business purposes, and mixed-use vehicles do not benefit from the accessory use exception if they do not transport goods.

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