Doctrine by topic · DGT Observatory

Tangible Fixed Assets: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 8 rulings · 2014–2019

Current position

The acquisition of used tangible fixed assets, such as real estate or vehicles, is eligible for the RIC under letter C of article 27.4 of Law 19/1994. To include the land value in the investment, rehabilitation works must increase the value of the asset. Transport elements, such as passenger vehicles for commercial promotion, are also considered eligible investments under this assumption.

The DGT's position has remained constant over time. Rulings confirm that used assets (real estate, plants, or vehicles) are not initial investments, but must be categorized under letter C of the regulation. No changes are observed in the interpretation of the materialization requirements.

Analysis based on 6 of 8 rulings with a stated position. Updated 30 September 2026.

Rulings on this topic

8

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