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Consumption: 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 8 rulings · 2016–2025

Current position

For an operation to be subject to IVA (Value Added Tax), there must be a consumption of goods or services by the payer. Contributions to cover expenses or subsidies without direct consideration do not constitute operations subject to the tax. In IRPF (Personal Income Tax), capital losses resulting from consumption are not accounted for, including the deterioration of durable consumer goods or the loss of value of rights that are consumed over time.

The DGT's position remains constant in defining consumption as an essential element for liability to IVA. Regarding IRPF, the doctrine confirms that consumption excludes certain capital losses, extending this concept to the deterioration of goods and the passage of time in rights of use.

Turning points

  1. V1231-23

    Clarifies that contributions to cover expenses do not remunerate services as there is no act of consumption that serves as effective consideration.

  2. V1182-25

    Establishes that the acquisition value of a right of use must be reduced by the time elapsed, as the right is consumed over time.

Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8

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