How the DGT's position has evolved
Current position
Investment in real estate for the Canary Islands Investment Reduction (RIC) requires that the asset be tangible fixed property, be used for the activity, and be necessary for it. If the property is used, it is only considered an initial investment if the entity is small-scale and the asset has not previously benefited from the RIC. In other cases, it must comply with the requirements of letter C of section 4 of article 27 of Law 19/1994.
The DGT's position on financial leasing is heterogeneous, as rulings address disparate aspects such as the Stamp Duty (AJD), IVA (Value Added Tax), IRPF (Personal Income Tax), and the RIC. There is no single doctrinal evolution regarding the concept of financial leasing, but rather an application of specific criteria depending on the tax matter addressed in each ruling.
Analysis based on 75 of 82 rulings with a stated position. Updated 23 September 2026.