Doctrine by topic · DGT Observatory

Basic Research: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

← DGT Observatory

How the DGT's position has evolved

Settled doctrine High confidence 9 rulings · 2014–2021

Current position

Basic research does not constitute a business activity if it is carried out without the objective of commercially exploiting the results and without performing onerous operations related to transactions subject to VAT. In these cases, the activity falls outside the scope of VAT. Public contributions to finance activities of general interest are not considered consideration for taxable operations.

The DGT's position remains constant in the distinction between basic and applied research. The evolution shows a consolidation of the criterion that basic research lacks a business character when there is no commercial exploitation of the results or onerous consideration. It has been reaffirmed that public contributions for general interest purposes do not generate tax liability.

Turning points

  1. V0369-19

    Establishes that basic research that does not seek to commercially exploit its results is not a business activity and falls outside the scope of VAT.

  2. V0720-19

    Specifies that basic research intended to transfer knowledge to society without the aim of commercial exploitation is not a business activity.

Analysis based on 9 of 9 rulings with a stated position. Updated 30 September 2026.

Rulings on this topic

9
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

Apply this to your case

VAT advisoryTalk to the team applying this doctrine daily.
Talk to the tax teamWe check whether this criterion affects you and what it means in your situation.
Email
Contact