Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The temporary importation regime with exemption from duties and IVA (Value Added Tax) requires that goods, such as vehicles or boats, be registered outside the customs territory of the Union and be used by persons not established in the Union. Obtaining a residence permit in Spain converts the holder into an established person, which prevents the use of this regime and triggers the accrual of IEDMT (Tax on the Importation of Motor Vehicles) and IVA. In the case of vehicles with tourist registration, use by residents must be occasional and at the request of the holder to avoid losing the exemption.
The DGT's position remains constant in requiring the non-residency of the holder to apply the exemption. Throughout the rulings, the limits of use by third parties have been specified, and it has been reinforced that obtaining residence in Spain breaks the condition of being non-established, thereby activating the tax. There are no changes in criterion, but rather a rigorous application of customs regulations regarding residence and registration.
Turning points
Specifies that a resident may use a vehicle with tourist registration as long as it is at the request of the holder, on an occasional basis, and for private purposes.
Establishes that obtaining a residence permit converts the holder into an established person, preventing the temporary importation regime and triggering the accrual of IEDMT.
Analysis based on 14 of 18 rulings with a stated position. Updated 25 September 2026.