Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The exemption for rental activity requires that the vehicle or vessel be allocated exclusively to said activity. The exemption is not lost due to related-party transactions if the transferee company manages the contracts with end customers and the owner has no rights of use. If the requirements are breached before the four-year period (or two years if the exemption was for rental activity), the owner must perform a self-assessment of the tax.
The DGT's position remains stable regarding the obligation to perform a self-assessment upon breach of requirements within the legal timeframes. Clarifications have been introduced to prevent the loss of the exemption due to related-party transactions, provided that the transferee manages the commercial activity autonomously.
Turning points
Clarifies that the exemption requirements are only mandatory to obtain the benefit, not preventing rental for periods exceeding three months if the vehicle has already been taxed normally.
Establishes that the exemption is not lost due to related-party transactions if the transferee enters into contracts with end customers and the owner receives no rights of use.
Analysis based on 9 of 12 rulings with a stated position. Updated 27 September 2026.