How the DGT's position has evolved
Current position
The leasing of land for business activities, such as the installation of solar panels, wind turbines, quarries, or parking lots, is subject to VAT at the general rate of 21% and does not benefit from the exemption for rural land. For IRPF (Personal Income Tax), this income constitutes income from real estate capital if it does not constitute an economic activity. The distinction of economic activity depends on the existence of an organization of means and the assumption of risk, or in the case of parking lots, on the hiring of personnel.
The DGT's position remains constant in excluding the VAT exemption when the use of the land is not agricultural, but is instead linked to a business or service activity. Rulings have detailed various specific scenarios, such as hunting, the installation of renewable energies, or vehicle parking, always confirming the application of the general rate. No changes in criterion are observed, but rather a uniform application of the rule to different land uses.
Analysis based on 18 of 20 rulings with a stated position. Updated 25 September 2026.