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Applied Research: 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

Settled doctrine High confidence 8 rulings · 2014–2021

Current position

Basic research is not a business activity if it is carried out without the objective of commercially exploiting the results and without performing onerous operations related to it. In these cases, the activity falls outside the scope of IVA (Value Added Tax). For applied research, the right to deduction depends on the foreseeable destination of the goods and services, allowing deduction if there is certainty of a future business exploitation.

The DGT's position remains constant regarding the distinction between basic and applied research. It has been reaffirmed that basic research without the aim of commercial exploitation or without onerous consideration does not constitute a business activity and falls outside the scope of IVA. The doctrine has focused on specifying that public contributions or subsidies do not constitute consideration for taxable operations.

Turning points

  1. V3982-15

    Establishes that if the results are offered without consideration, such as publication in journals for general knowledge, the activity falls outside the scope of the tax.

  2. V0369-19

    Specifies that basic research that does not seek to commercially exploit its results is not a business activity and that public contributions for the general interest are not taxable considerations.

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

Rulings on this topic

8
V2555-14 30 Sept 2014

Input VAT is deductible if used in taxable and non-exempt activities

SG de Impuestos sobre las Personas Jurídicas
actividad empresarialinvestigación básicainvestigación aplicadadeducción de cuotasoperaciones sujetas y no exentas LIVA — Ley 37/1992 del IVA art. 4LIVA — Ley 37/1992 del IVA art. 5
Affects CompanyExpat · Non-residentIndividual

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