How the DGT's position has evolved
Current position
Legal entities must be taxed on professional activities through the business section of the tax. In the case of residential leases, the 50% reduction is applicable if it is proven that the property is used exclusively as the residence of a specific natural person. Likewise, companies are obliged to receive notifications by electronic means.
The DGT's position does not show a single doctrinal evolution, as the rulings address heterogeneous matters such as the NIF, withholding, tax registration, or electronic notification. There is no change of criterion regarding a central concept, but rather a dispersion of regulatory applications for different scenarios involving the legal entity.
Analysis based on 45 of 46 rulings with a stated position. Updated 23 September 2026.