How the DGT's position has evolved
Current position
The right to deduct input VAT (IVA) is conditional upon the operations being taxable and not exempt. If the taxable person simultaneously carries out operations with a right to deduction and others that are exempt, they must apply the general or special pro-rata rule. In the event that differentiated sectors exist, a separate deduction regime must be applied to each of them.
The DGT's position has remained constant over time. Consultations repeatedly confirm the application of the pro-rata rule when activities with and without a right to deduction coexist. No changes in the interpretation of the rule are observed, but rather a systematic application of the scenarios set out in the VAT Law (Ley del IVA).
Analysis based on 61 of 63 rulings with a stated position. Updated 21 September 2026.