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Tonnage Regime: 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 · 2015–2023

Current position

To apply the tonnage regime, the entity must carry out strategic and commercial management from Spain or the EU/EEA, assuming control and risk of the maritime activity. In the case of dredgers, transport income between extraction and deposit is included in the 50% limit for maritime transport income. In the event of the transfer of vessels, the unavailable reserve and the difference in income corresponding to the taxation period under the general regime must be included in the tax base.

The DGT's position remains stable regarding the requirements for management and nautical exploitation. The evolution focuses on the precision of operational concepts, such as the calculation of income for dredgers, and on the definition of tax consequences in the event of the transfer of vessels that have alternated between regimes.

Turning points

  1. V0131-17

    Establishes that for dredgers, transport between extraction and deposit is considered maritime transport for the calculation of the income limit.

  2. V1202-23

    Determines the tax treatment in the transfer of vessels, requiring the integration of the unavailable reserve and the difference in income for the periods under the general regime.

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

Rulings on this topic

8
V0987-15 27 Mar 2015

Tonnage scheme vessels may be managed or registered within the European Economic Area

SG de Impuestos sobre las Personas Jurídicas
régimen especial de entidades navierasgestión estratégica y comercialbuques de remolquebuques de dragadoespacio económico europeo LIS — Ley 27/2014 del Impuesto sobre Sociedades art. 113.2LIS — Ley 27/2014 del Impuesto sobre Sociedades art. 114.2
Affects CompanyExpat · Non-residentIndividual

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