How the DGT's position has evolved
Current position
For passenger vehicles, a 50% business use allocation is presumed, except in cases of total allocation as specified by law. The taxpayer may prove a different degree of use, whether higher or lower, through any means of evidence admitted in Law. The deduction of related expenses, such as fuel or repairs, is decoupled from the acquisition of the vehicle and depends on its own allocation to the business activity.
The DGT's position has remained constant over time regarding the 50% presumption for passenger vehicles. The doctrine has reiterated that this percentage is subject to modification if a different degree of use is proven through means of evidence. No changes have been observed regarding the requirement to prove the allocation of expenses derived from the vehicle.
Analysis based on 11 of 11 rulings with a stated position. Updated 29 September 2026.