How the DGT's position has evolved
Current position
Repair and maintenance expenses are deductible if they are aimed exclusively at the future generation of income and not at the enjoyment of the owner. Any excess in deductible expenses may be offset in the following four years. In the professional sphere, funds for disbursements received to make payments on behalf of the client do not constitute income from economic activity. Finally, deductible work expenses are exclusively those listed in article 19.2 of the LIRPF (Personal Income Tax Law), excluding concepts such as master's degree tuition.
The DGT's position does not show a doctrinal evolution regarding a single concept, but rather addresses various and specific criteria depending on the nature of the income. A strict application of the regulations is observed regarding work expenses, along with a clear delimitation of deductible expenses in real estate and professional income.
Turning points
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Specifies that repair expenses carried out before the lease are deductible if they are aimed at the future generation of income and the owner proves the expectation of rental.
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Establishes that funds for disbursements intended to make payments on behalf of the client do not have the nature of income from economic activity.
Analysis based on 60 of 61 rulings with a stated position. Updated 18 September 2026.