How the DGT's position has evolved
Current position
Taxpayers may prove the status of a reusable container or any fact constituting their rights through any means of evidence admissible under Law, including certificates from accredited entities. The Administration applies the principle of free and joint assessment to determine the validity and sufficiency of such evidence. The final assessment of the means provided rests with the tax application bodies.
The DGT's position has remained constant over time, reaffirming that there are no specific means of evidence and that the freedom of assessment prevails. The evolution shows an application of this general principle to specific cases, such as the status of a reusable container, where the use of certificates from accredited entities is explicitly admitted.
Turning points
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It is specified that, among the admissible means, certificates issued by accredited entities may be used to prove the status of a reusable container.
Analysis based on 27 of 27 rulings with a stated position. Updated 24 September 2026.