Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The deduction of passenger car expenses requires exclusive use for the economic activity, subject to regulatory exceptions, and such exclusivity must be proven through means of evidence. Regarding the exemption of income, partially exempt entities must pay tax on income derived from economic activities or income that does not belong to their corporate purpose. Regarding reductions for irregular income, these are not applicable if the earnings come from an economic activity that obtains them in a regular or habitual manner.
The sequence does not show a doctrinal evolution on a single concept, but rather addresses diverse matters within the scope of economic activity. A tendency is observed towards requiring proof of exclusive use for vehicle expenses and a strict delimitation of exempt income versus income derived from economic activities. There is no change in criterion, but rather a thematic dispersion in the rulings.
Turning points
Establishes that exclusive use for the deduction of vehicle expenses must be proven through means of evidence admitted by law.
Specifies that ownership of another private-use vehicle does not serve to prove the exclusive use of the vehicle assigned to the activity.
Analysis based on 41 of 45 rulings with a stated position. Updated 19 July 2026.