How the DGT's position has evolved
Current position
The VAT exemption on the leasing of residential properties depends on the effective and direct use by the lessee as the final consumer. In the transfer of buildings, the delivery is subject to VAT if the acquirer intends to rehabilitate the property. The nature of the exemption is purpose-driven and requires that the use be necessary and direct for the lessee.
The sequence does not show a doctrinal evolution regarding a single concept, but rather presents scattered criteria on different exemption scenarios (sports services, shows, leases, dation in payment, orthodontics, and rehabilitation). There is no trajectory of change or refinement applicable to a unified topic, but rather a series of rulings on diverse matters.
Analysis based on 437 of 462 rulings with a stated position. Updated 12 November 2026.