How the DGT's position has evolved
Current position
The classification within the IAE (Business Activity Tax) Rates is determined by the activity actually performed. Unspecified activities are classified under the most similar heading or under the heading for activities not classified elsewhere (n.c.o.p.). The distinction between professional and entrepreneur depends on whether the activity is carried out personally or through an organization detached from the individual's personality.
The DGT's position remains constant in applying the nature of the activity to determine the heading. The rulings show a technical and specific application of the Rates to concrete cases such as gardening services, plastic manufacturing, or professional services. No doctrinal changes are observed, but rather a repeated application of the criteria of similarity and specificity.
Analysis based on 91 of 98 rulings with a stated position. Updated 21 September 2026.