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General Expenses: 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

Stable position High confidence 8 rulings · 2016–2026

Current position

General expenses are deductible if they represent a general benefit for the entrepreneur, even without a direct relationship with taxable operations, by applying the pro-rata rule. In the case of holdings, for these expenses to be deductible, their cost must form part of the constituent elements of the price of the operations that entitle the right to deduction. In SAT (Societies of Professional Services), the price of services to partners must be equal to or higher than the cost, including the portion of general expenses.

The DGT's position remains stable regarding the nature of general expenses as deductible elements through pro-rata when they benefit the activity. No doctrinal change is observed, but rather an application of the concept to different sectors such as holdings, real estate, or SAT. The doctrine requires that the expense be linked to the economic activity or integrated into the price of the services provided.

Turning points

  1. V1468-23

    Specifies that general expenses are deductible even if they do not have a direct and immediate relationship with taxable operations, provided they represent a general benefit for the entrepreneur.

  2. V1640-24

    Establishes that for holdings, the cost of general expenses must form part of the constituent elements of the price of the operations that entitle the right to deduction.

Analysis based on 8 of 8 rulings with a stated position. Updated 1 October 2026.

Rulings on this topic

8
V5033-26 12 Jun 2026

Agricultural transformation societies may use effective price for services

SG de Impuestos sobre las Personas Jurídicas
sociedad agraria de transformaciónvalor de mercadocoste de serviciosgastos generalesrégimen fiscal de cooperativas Ley 20/1990 Régimen Fiscal de CooperativasLIS — Ley 27/2014 del Impuesto sobre Sociedades art. 7.1.b
Affects CompanyExpat · Non-residentIndividual
V1468-23 31 May 2023

Overhead costs are deductible using the pro rata method

SG de Impuestos sobre el Consumo
gastos generalesderecho a la deducciónregla de prorrataoperaciones exentassujeto pasivo LIVA — Ley 37/1992 del IVA art. 4.UnoLIVA — Ley 37/1992 del IVA art. 5.Uno
Affects CompanyExpat · Non-residentIndividual

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