How the DGT's position has evolved
Current position
Regarding VAT (IVA), mixed vehicles benefit from a presumption of 100% business use only if they are intended for the transport of goods (items for trade). If they are used to transport materials or tools, the presumption is 50%, although a higher business use can be proven. Regarding Personal Income Tax (IRPF), mixed vehicles intended for the transport of goods are exempt from the limitation regarding accessory private use.
The DGT's position remains constant in the distinction between the transport of goods and the transport of tools. It has been reaffirmed that the transport of materials or tools does not allow for the 100% presumption in VAT, maintaining the 50% presumption. The doctrine is stable regarding the need for exclusive business use for the deductibility of expenses in IRPF, except in the case of mixed vehicles intended for goods.
Turning points
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Clarifies that the transport of materials or tools does not constitute the transport of goods, limiting the presumption of business use to 50%.
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Establishes that if the mixed vehicle is used for tools, the exception for accessory personal use does not apply and exclusive business use is required.
Analysis based on 16 of 20 rulings with a stated position. Updated 25 September 2026.