How the DGT's position has evolved
Current position
In intra-Community acquisitions, it is possible to reduce the quotas accrued for products sent outside the territory of application of the tax, provided that the shipment or transport and the prior payment of the tax are proven. In the scope of IRNR (Non-Resident Income Tax), the IRPF (Personal Income Tax) payments on account made before proving the change of residence are deductible from the IRNR quota if they correspond to income subject to said tax.
The DGT's position does not show a doctrinal evolution regarding a single concept, as the rulings address different deduction matters (IVA [VAT], IRPF, ISD [Gift and Inheritance Tax], and IRNR). The criteria remain consistent in their respective areas, treating the deduction as a direct consequence of complying with requirements regarding the allocation or proof of the transaction.
Analysis based on 43 of 47 rulings with a stated position. Updated 15 September 2026.