How the DGT's position has evolved
Current position
The deductibility of IVA (Value Added Tax) in passenger vehicles is governed by a presumption of 50% business use if the transfer is free of charge or carried out through benefits in kind without direct payment. For the transfer of a vehicle to be an onerous operation for IVA purposes, the employee must make a payment or have a portion of their salary deducted. Derived expenses, such as fuel or repairs, require proof of business use and invoices that comply with the Invoicing Regulations.
The DGT's position remains stable regarding the 50% presumption of business use for passenger vehicles. The doctrine has specified that the deductibility of ancillary expenses depends on proof of business use and that the onerous nature of vehicle transfers in benefits in kind requires an effective payment or salary deduction.
Turning points
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Establishes the 50% presumption of business use for passenger vehicles and separates the right to deduct fuel expenses from the acquisition of the vehicle.
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Clarifies that it is not mandatory to include the license plate number on fuel invoices, although it serves as a supporting element of business use.
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Specifies that benefits in kind do not automatically imply an onerous operation for IVA, requiring a payment or salary deduction to break the presumption of being free of charge.
Analysis based on 70 of 75 rulings with a stated position. Updated 3 September 2026.