Skip to content
Back to index
V5246-26 23 July 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · arrendamiento operativo

Operating leases of vessels considered services, not goods delivery

A company asks about the classification of an operating lease of boats and recreational vessels, and the applicable amortisation coefficients under Corporate Tax. The DGT clarifies that, due to the absence of a binding transfer of ownership clause, the arrangement is classified as a service for VAT purposes and determines amortisation coefficients based on vessel length.

The question raised

Question raised 1. Can the operating lease transaction be classified as a supply of goods for Value Added Tax purposes?

The DGT's ruling

An operating lease without a purchase option or a binding property transfer clause is classified as a provision of services. If, upon expiration of the contract, the asset is sold to the lessee at market price, the supply of goods shall occur at the time of said sale. Regarding Corporate Income Tax, pleasure crafts (length ≥ 24m) are depreciated as "ships, aircraft" (10% straight-line), whereas pleasure boats (< 24m) are considered "external transport elements" (16% straight-line).

Free assessment and quote