Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
Vessels intended for nautical charter are exempt from IEDMT (Tax on the Transmission of Property and Deeds) if they are exclusively used for the rental activity. The exemption is not lost through transfers to related parties, provided they are not residents in Spain nor holders of establishments in Spanish territory. The taxable event only occurs when the use in Spain is carried out by residents or holders of establishments in Spain.
The DGT's position remains stable regarding the requirement of exclusive use for the rental activity. It has been specified that the relationship with the transferee company does not invalidate the exemption if it manages the contracts with end customers and the owner does not enjoy the use of the vessel. The doctrine confirms that use by non-residents does not trigger the tax accrual.
Turning points
Establishes that the exemption requires effective and exclusive use, noting that a right of reservation with special conditions for the owner fails to meet this requirement.
Clarifies that the exemption is not lost due to a related-party relationship if the transferee enters into contracts with end customers and the owner does not receive usage rights.
Analysis based on 11 of 14 rulings with a stated position. Updated 27 September 2026.