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Tangible Assets: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 14 rulings · 2014–2026

Current position

The tax relief under Article 26 of Law 19/1994 requires an industrial activity of producing tangible assets through a manufacturing process that transforms raw materials into products with distinct characteristics. In the case of meat butchery, the activity must be registered under the heading for industries of utilization and transformation, considering the manufacturing of preserves if the packaging includes sterilization or pasteurization.

The DGT's position remains constant in requiring an industrial transformation activity to access the tax relief. The criterion has evolved from defining the manufacturing of prostheses or lamps to specifying technical requirements in the meat sector, such as the need for registration under utilization and transformation headings.

Turning points

  1. V5185-26

    Specifies that meat butchery requires registration under utilization and transformation headings, and that sterilization or pasteurization during packaging constitutes the manufacturing of preserves.

Analysis based on 14 of 14 rulings with a stated position. Updated 26 September 2026.

Rulings on this topic

14

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