How the DGT's position has evolved
Current position
The right to deduct input VAT may be exercised in the period of accrual or in subsequent periods within a four-year period. This period is interrupted in the event of administrative or judicial controversies. Deductibility requires the objective intention to allocate the assets to the activity and the possession of supporting documentation.
The DGT's position remains constant regarding the exercise of the right to deduction and its deadlines. Clarifications have been added concerning the interruption of the four-year period due to inspections or controversies, and regarding the deductibility of acquisitions made prior to the start of activity with the intention of allocation.
Turning points
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Specifies that the four-year period is interrupted from the notification of the start of the inspection proceedings until the final resolution.
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Establishes that input VAT incurred prior to the start of operations is deductible if there is an objective intention to allocate it to the activity.
Analysis based on 45 of 45 rulings with a stated position. Updated 23 September 2026.