How the DGT's position has evolved
Current position
The first registration of N1 vehicles is not subject to the IEDMT (Tax on Motor Vehicle Transfers) if they are significantly used for an economic activity, a situation presumed if at least 50% of the VAT is deducted. In the case of used vehicles, the tax base is their market value, determined by valuation tables or the value agreed upon between independent parties. For vehicles adapted for wheelchairs, non-subjectivity requires that they are specifically designed and constructed for that use, with a curb weight of less than 350 kg and a maximum speed of 45 km/h.
The DGT's position does not show a single doctrinal evolution, but rather addresses various scenarios such as the exemption for economic activity, the non-subjectivity of adapted vehicles, or the accrual in vessels. Greater precision is observed in the determination of the tax base for used vehicles and in the presumption of economic use for N1 vehicles in the most recent rulings.
Turning points
-
Establishes that vehicles adapted for wheelchairs only enjoy non-subjectivity if they are specifically designed and constructed for that use, with weight and speed limits.
-
Specifies that the significant use of N1 vehicles is presumed if at least 50% of the VAT is deducted and defines the market value for used vehicles.
Analysis based on 25 of 28 rulings with a stated position. Updated 24 September 2026.