How the DGT's position has evolved
Current position
The deductibility of expenses depends on the direct and exclusive use for the activity, except for specific legal presumptions. For passenger cars, a 50% business use is presumed, whereas mixed vehicles intended for the transport of goods or those used by commercial agents are presumed to have 100% business use. To prove degrees of use different from the presumption, reliable evidence is required; mere accounting entries are not sufficient.
The DGT's position remains stable regarding the rules of presumption of business use for vehicles. There is an insistence on the need to prove actual business use versus mere accounting declaration. Recent doctrine specifies that the nature of the asset (such as the duration of its use) determines the application of the rules for investment and deduction.
Turning points
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Establishes that mere declaration-settlement or accounting entries are not sufficient means of proof to certify a degree of business use different from 50% for passenger cars.
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Determines that if a vehicle is transferred on the same day as its acquisition, it is not an investment asset and the 50% presumption does not apply.
Analysis based on 62 of 66 rulings with a stated position. Updated 12 September 2026.