How the DGT's position has evolved
Current position
The deductibility of expenses requires proving their relationship to the generation of income and their exclusive use for the economic activity. Regarding income from employment (IRPF), the list of deductible expenses is exhaustive and does not include concepts such as master's degree tuition fees. For passenger vehicles, the use must be exclusive and proven through means of evidence; otherwise, no expense deduction is permitted.
The DGT maintains a restrictive stance based on the correlation of income and exclusive use. A clear distinction is observed between the exhaustive list of expenses for income from employment and the need to prove the link of expenses in economic activities. The position on vehicles and social security contributions remains constant in its requirement for causality and specific regulations.
Turning points
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Establishes that the expenses of a passenger vehicle are not deductible if the sole shareholder has no employment relationship, classifying it as remuneration from equity.
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Specifies that if a vehicle is used for private needs, it is not considered dedicated to the activity and no expense may be deducted.
Analysis based on 23 of 23 rulings with a stated position. Updated 25 July 2026.