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Storage: 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

Stable position Medium confidence 9 rulings · 2014–2025

Current position

Storage in cold storage chambers is not considered a service related to real estate if there is no transfer of a specific and exclusive physical space. In the absence of exclusivity, the location is governed by the general rule of Article 69.One of Law 37/1992. On the other hand, subsidies for storage using renewable sources under Royal Decree 477/2021 are not included in the taxable base of IRPF (Personal Income Tax).

The DGT's position does not show a coherent doctrinal evolution on a single concept of storage, but rather addresses different aspects. It has moved from defining the non-existence of a permanent establishment through logistics services to specifying the nature of specific services, such as storage in cold storage chambers or the tax treatment of subsidies for energy storage.

Turning points

  1. V0671-16

    Establishes that a physical space for the connection and storage of items is considered a premises, qualifying the activity as trade in a permanent establishment.

  2. V2180-24

    Specifies that storage in cold storage chambers is only a service related to real estate if it involves the transfer of a specific and exclusive physical space.

Analysis based on 9 of 9 rulings with a stated position. Updated 28 September 2026.

Rulings on this topic

9
V2224-25 19 Nov 2025

Subsidies under Royal Decree 477/2021 for self-consumption are IRPF-exempt

SG de Impuestos sobre la Renta de las Personas Físicas
base imponiblesubvenciónautoconsumoenergías renovablesexención LIRPF — Ley 35/2006 del IRPF art. disposición adicional 5ª.4LGT — Ley 58/2003 General Tributaria art. 89.1
Affects CompanyExpat · Non-residentIndividual

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