How the DGT's position has evolved
Current position
The leasing of assets is considered a provision of services subject to the general VAT (IVA) rate of 21% when the lessor acts as an entrepreneur or professional. In the case of deposits for the return of goods, such as pallets, the deposit constitutes an actual credit that must be included in the tax base, and the tax amounts must be rectified when the refund occurs.
The DGT's position remains stable regarding the classification of the leasing of assets and parking spaces as provisions of services subject to VAT (IVA). No significant doctrinal changes are observed, but rather a constant application of the entrepreneur status to the lessor to determine the tax liability.
Analysis based on 61 of 63 rulings with a stated position. Updated 22 September 2026.