How the DGT's position has evolved
Current position
The deductibility of expenses and investments in patrimonial assets requires their direct allocation to the economic activity and proof of their exclusive or professional use. In the case of vehicles, the 50% allocation presumption applies to mixed-use vehicles, unless a different use is demonstrated. Income derived from these assets is attributed according to the rules of legal ownership.
The DGT's position remains stable regarding the need to prove the allocation of patrimonial assets for their deductibility. A trend is observed towards requiring more rigorous means of proof to rebut presumptions of personal use, especially in vehicles. The criterion regarding the nature of patrimonial assets and their tax treatment has remained constant in the analyzed rulings.
Turning points
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Establishes the 50% allocation presumption for mixed-use vehicles, allowing 100% if used for the transport of goods.
Analysis based on 46 of 50 rulings with a stated position. Updated 18 September 2026.