Doctrine by topic · DGT Observatory

General Interest Purposes: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 11 rulings · 2015–2023

Current position

To fulfill general interest purposes, the entity must carry out activities directly or indirectly through other entities covered by Law 49/2002. In indirect execution, it is mandatory to exercise active monitoring and control over the projects and the destination of the funds. Activities such as the promotion of commercial companies or commercial advertising are not considered general interest purposes.

The DGT's position remains constant in requiring activities to be carried out directly or through other entities under Law 49/2002 with active control. Coherence has been maintained regarding the exclusion of commercial companies in indirect execution and the need to prove the facts before the Administration.

Turning points

  1. V2106-15

    Establishes that indirect execution is possible if carried out through entities under Law 49/2002 and if there is active monitoring and control of the projects.

Analysis based on 11 of 11 rulings with a stated position. Updated 28 September 2026.

Rulings on this topic

11

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