How the DGT's position has evolved
Current position
The free delivery of goods from business assets is considered an operation assimilated to a delivery of goods for consideration (self-consumption). This operation is subject to IVA (Value Added Tax) when carried out by entrepreneurs or professionals in the course of their activity. In the case of buildings, if it is the first delivery following their construction, the operation is taxable and not exempt. The tax accrual occurs upon the change of ownership or change of use.
The DGT's position remains constant in classifying the free delivery of goods from business assets as self-consumption subject to IVA. Rulings have applied this concept to various scenarios, such as the transfer of premises, vehicles, or the distribution of goods between parent companies and subsidiaries. No changes in criterion are observed, but rather a repeated application of the concept to diverse types of goods.
Analysis based on 28 of 31 rulings with a stated position. Updated 24 September 2026.