How the DGT's position has evolved
Current position
The 10% reduced rate applies to passenger transport services, construction works or renovation of dwellings with residential suitability, and certain food supplies with auxiliary services. Medical equipment only benefits from this rate if specifically included in the Annex of the Law. Hairdressing and gym services are taxed at the general rate of 21%.
The DGT does not show a doctrinal evolution regarding a single concept, but rather applies specific and differentiated criteria for each analyzed case of the reduced rate. The rulings maintain a strict application of the IVA (Value Added Tax) Law, requiring compliance with technical or classification requirements to use rates lower than 21%.
Turning points
-
Clarifies that hairdressing services are not considered social assistance or residential care, and therefore are taxed at 21%.
-
Establishes that the suitability of a dwelling for the 10% rate is determined by objective design characteristics and not by the certificate of habitability.
Analysis based on 73 of 79 rulings with a stated position. Updated 4 September 2026.