How the DGT's position has evolved
Current position
The reduced rate of 10% applies to the execution of construction or renovation works of buildings intended for housing, provided that the contract is formalized directly between the developer and the contractor. In the case of renovation, the main object must be reconstruction and the cost must exceed 25% of the value of the property excluding the land. Likewise, the 10% rate applies to waste management services and to certain supplies of prepared food.
The DGT's position does not show a doctrinal evolution on a single concept, but rather the sequence presents scattered criteria on different scenarios of the reduced rate. A tendency toward technical precision is observed regarding the requirements for renovation and the contractual structure necessary to apply the 10% rate to works.
Turning points
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Establishes that in housing cooperatives, if the builder invoices the member directly, the right to the 10% rate is lost because there is no direct contract with the developer.
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Defines the quantitative thresholds for renovation: reconstruction of more than 50% of structural elements and a cost exceeding 25% of the value of the property.
Analysis based on 59 of 67 rulings with a stated position. Updated 9 September 2026.