Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The first final registration of a vessel is not subject to IEDMT (Tax on the Transfer of New Goods) if it is proven that the tax for circulation or use in Spain has already been self-assessed and paid pursuant to Article 65.5 of Law LIE. In other cases, such as the disability exemption, the requirements must be met and proven via form 05 before registration to avoid the obligation of self-assessment. For electric vehicles, the tax rate is 0% if no specific exemption applies.
The DGT's position remains stable regarding the determination of the taxable event through registration or use in Spanish territory. Rulings have progressively specified the exemption scenarios and the conditions to avoid double taxation on vessels. No change in criterion is observed, but rather an application of the regulations to different scenarios such as the rental regime, disability, or temporary importation.
Turning points
Establishes that in the event of the impossibility of recovering a foreign registration due to the repeal of special regimes, vehicles must obtain an ordinary Spanish registration.
Clarifies that the exemption requirements of Article 66.1.c) of Law LIE only apply if an exemption is sought, allowing rentals exceeding three months if taxed normally.
Analysis based on 27 of 32 rulings with a stated position. Updated 24 September 2026.