How the DGT's position has evolved
Current position
For an activity to be subject to the IAE (Tax on Economic Activities), there must be the management on own account of means of production or human resources. Professionals acting in a personal capacity and without a business organization must register in the second section of the Tariffs. If the activity is carried out through an organization, it is classified as a business activity.
The DGT's position remains constant in the definition of economic activity, requiring the management of means to differentiate it from employment dependency. Recent rulings maintain this criterion and focus on the correct classification of headings according to the nature of the service. No changes in the base doctrine have been observed since 2015.
Analysis based on 16 of 16 rulings with a stated position. Updated 26 September 2026.