How the DGT's position has evolved
Current position
The taxpayer may opt for the national rate if their activity is assigned several types of rates, allowing them to carry out the activity throughout the national territory without paying a municipal or provincial rate. For this change to take effect, a declaration of variation must be submitted. The determination of the rate depends on the nature of the activity, whether by surface area, power, or number of seats.
The DGT's position remains stable regarding the option to choose the national rate when different types of rates are assigned. The analyzed rulings do not show a change in doctrine, but rather address different factual scenarios such as the calculation of surface areas, the determination of headings, or the application of reductions according to the type of activity.
Analysis based on 11 of 12 rulings with a stated position. Updated 27 September 2026.