How the DGT's position has evolved
Current position
To access energy efficiency deductions, the taxpayer must hold the status of homeowner. The tenant does not meet the ownership requirement necessary to apply the deductions of the fiftieth additional provision of the LIRPF (Personal Income Tax Law). In the case of the deduction for rental of a habitual residence, the status of tenant is held solely by the signatory of the contract.
The DGT's position remains constant in requiring specific requirements depending on the type of deduction. The doctrine that the status of tenant is exclusive to the signatory of the contract (V0219-15, V1954-18) is maintained, and it is confirmed that the tenant lacks the right to deductions for rehabilitation works (V1212-26).
Turning points
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Establishes that the status of tenant is held solely by the signatory of the contract, following the doctrine of the Supreme Court.
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Defines that the primary purpose must be to satisfy the tenant's permanent housing need, excluding contracts with commercial companies for employees.
Analysis based on 15 of 16 rulings with a stated position. Updated 26 September 2026.