How the DGT's position has evolved
Current position
Classification in the IAE is determined by the true material nature of the activities. In the case of training, the heading depends on whether it is professional refinement, general teaching, or if it is carried out without a permanent establishment. Training activities funded exclusively by the INE or the European Social Fund are not considered teaching and do not accrue tax liability.
The DGT's position remains constant by applying the principle of the material nature of the activity for classification. No doctrinal changes are observed, but rather a technical application of the rates to different scenarios such as manufacturing, energy production, or training. The doctrine is stable in its classification methodology.
Turning points
-
Specifies that the commencement of activity for photovoltaic production occurs with the effective production of energy, excluding construction or licensing phases.
-
Establishes that training funded exclusively by the INE or the European Social Fund is not considered a teaching activity and does not accrue tax liability.
Analysis based on 34 of 34 rulings with a stated position. Updated 20 July 2026.