How the DGT's position has evolved
Current position
The reduced rate of 10% requires that the good be capable of direct, habitual, and suitable use in agricultural, forestry, or livestock activities due to its characteristics, packaging, and state. Furthermore, the product must fall into the categories of fertilizers, organic waste, conditioners, soil improvers, herbicides, or pesticides. If the product has a mixed use with gardening or does not fit these categories, the general rate of 21% for Value Added Tax (IVA) applies.
The DGT's position remains constant regarding the application of the reduced rate. Throughout the rulings, the need for products to meet technical suitability requirements and fit into specific categories has been reiterated. The doctrine has maintained the exclusion of products with a mixed use intended for gardening.
Turning points
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Clarifies that earthmoving for reservoirs or the construction of fattening pens does not constitute agricultural activity, limiting the use of subsidized diesel.
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Establishes that if peat has a mixed use or is suitable for gardening without a business purpose, it must be taxed at the general rate of 21%.
Analysis based on 24 of 25 rulings with a stated position. Updated 24 September 2026.