How the DGT's position has evolved
Current position
Regarding VAT (IVA), passenger cars have a presumption of business use of 50%, although the taxable person may prove a different degree through means of evidence. The deduction of expenses such as fuel or repairs depends on their own actual use in the activity and not on the percentage of use of the vehicle. Regarding Personal Income Tax (IRPF), the deduction of expenses and depreciation requires that the vehicle be an asset used exclusively for the economic activity.
The DGT's position remains constant in the distinction between the treatment of VAT (IVA) and Personal Income Tax (IRPF). The 50% presumption for VAT (IVA) and the requirement of exclusive use for IRPF have been maintained. Recent rulings reaffirm that the deductibility of maintenance and fuel expenses is decoupled from the percentage of vehicle use.
Turning points
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It is established that for passenger cars or off-road vehicles, exclusive use for the activity is required, which must be proven through means of evidence admitted by law.
Analysis based on 19 of 20 rulings with a stated position. Updated 25 September 2026.