How the DGT's position has evolved
Current position
For the deductibility of passenger vehicle expenses, affectation is valid if private use is ancillary and notoriously irrelevant. Under the special regime for asset contributions, real estate must be assigned to an economic activity for at least three years. Real estate leasing activity is considered economic only if it has at least one full-time employee. If the activity ceases to be economic, the calculation of the affectation period is interrupted.
The DGT's position has evolved from requiring the exclusive use of vehicles toward accepting ancillary and irrelevant private use. Regarding the affectation of real estate, the requirement to have full-time staff to qualify the activity as economic has been consolidated. Likewise, it has been specified that the loss of said economic activity status interrupts the affectation period required for special regimes.
Turning points
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Allows the affectation of passenger vehicles if private use is ancillary and notoriously irrelevant, relaxing the requirement of absolute exclusivity.
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Establishes that if the activity ceases to be economic, the three-year affectation period is interrupted and must be recalculated.
Analysis based on 41 of 48 rulings with a stated position. Updated 21 September 2026.