How the DGT's position has evolved
Current position
The territorial scope of application for tax and collection obligations is determined by the location of the activity or the competence of the entity. In the case of irrigation communities, their power of enforcement is strictly limited to the territorial areas where they exercise their competencies. Regarding the IAE (Economic Activities Tax), the payment of the national quota allows for the exercise of the activity throughout the entire territory without local minimum quotas for that same heading.
The DGT's position does not show a doctrinal evolution regarding a single concept, but rather applies specific territoriality criteria depending on the subject matter. A constant application of territorial delimitation is observed for tax exemptions (IVA/gases), the determination of agricultural indices by municipality, and the limitation of the collection competencies of public entities.
Analysis based on 12 of 13 rulings with a stated position. Updated 27 September 2026.