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Direct and Exclusive Use: 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 11 rulings · 2016–2024

Current position

For the deduction of Value Added Tax (IVA), goods or services must be used directly and exclusively for professional activity. Partial use is only admitted in the case of investment goods, allowing for a proportional deduction. The use must be proven by any means admitted in Law, and mere accounting entries or the tax return-settlement are not sufficient.

The DGT's position remains constant in requiring direct and exclusive use for the deduction of IVA. The evolution shows greater precision in distinguishing between investment goods, which allow for partial use, and other goods or services that do not. The need to prove use through means of evidence additional to accounting is reinforced.

Turning points

  1. V0119-20

    Establishes that the degree of use must be proven by any means admitted in Law, clarifying that accounting entries or the tax return-settlement are not sufficient.

Analysis based on 9 of 11 rulings with a stated position. Updated 29 September 2026.

Rulings on this topic

12
V0260-22 14 Feb 2022

Deductibility of IRPF and VAT on purchase of a property for professional activity

SG de Impuestos sobre la Renta de las Personas Físicas
elementos patrimoniales afectosamortizaciónbien de inversiónderecho a la deducciónafectación directa y exclusiva LIRPF — Ley 35/2006 del IRPF art. 28LIRPF — Ley 35/2006 del IRPF art. 29.1.a
Affects CompanyExpat · Non-residentIndividual

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