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V0694-25 15 April 2025 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · amortización

Vehicle tourism expenses not deductible without employment relationship

A consultancy asks whether it can deduct 100% the purchase and costs of a used vehicle used by its sole shareholder for professional purposes. The DGT responds that these expenses are not deductible.

The question raised

Question posed: Whether both the purchase of said vehicle and the regular expenses incurred (fuel, technical inspection, repairs...) can be 100% deductible.

The DGT's ruling

Depreciation expenses from the purchase and usage expenses (fuel, technical inspection, repairs) of a passenger vehicle are not deductible if the sole shareholder does not maintain an employment relationship with the company. In the absence of an employment relationship, the assumption of these expenses by the company is considered remuneration to equity pursuant to Article 15.1.a) of the Corporate Income Tax Act.

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