How the DGT's position has evolved
Current position
The transfer of hunting rights over assets of a patrimonial nature is subject to IVA (Value Added Tax) at the general rate of 21%, as the object is the exploitation and not the leasing of land. If the transfer is carried out through an administrative concession over public domain assets, the operation is not subject to the tax. The gathering of cochinillas in the natural environment is treated as hunting exploitation.
The DGT's position has remained constant since 2014, always distinguishing between public domain assets (not subject to tax) and patrimonial assets (subject to IVA). There have been no changes in the classification of the activity as not exempt because it is not a land lease. The latest ruling introduces the classification of the gathering of cochinillas within this scope.
Turning points
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Includes the gathering of cochinillas in the natural environment as a hunting exploitation activity.
Analysis based on 16 of 17 rulings with a stated position. Updated 25 September 2026.