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V3057-14 7 November 2014 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IVA · afectación

VAT deduction for mixed-use vehicles is limited to 50%, unless used for goods transport

A taxpayer queried the VAT and Personal Income Tax (IRPF) deductibility of a mixed-use vehicle for their business activity. The Directorate General for Taxes (DGT) ruled that VAT is deductible at 50% based on a legal presumption, unless the vehicle is used for the transport of goods. Regarding IRPF, expenses are only deductible if the vehicle is used exclusively for the business activity.

The question raised

Deductibility of expenses derived from the purchase of the vehicle for VAT and IRPF purposes.

The DGT's ruling

In VAT, passenger and mixed vehicles carry a 50% presumption of business use, unless they are intended for the transport of goods (understood as goods subject to trade), in which case the presumption is 100%. In Personal Income Tax (IRPF), to deduct depreciation and usage expenses, the vehicle must be an asset used for business purposes, which requires exclusive use for the activity if legal exceptions are not met. If the mixed vehicle is used for materials or tools, it is not considered transport of goods and does not benefit from the exception for ancillary use in IRPF.

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