El TEAC amplía el criterio de cuándo puede entenderse como afecto a la actividad económica del titular el vehículo mixto de albañiles o fontaneros
Uso exclusivo y afectación a la actividad en el IRPF
Según la normativa del Impuesto sobre la Renta de las Personas Físicas (IRPF), solo puede considerarse que un bien —como un vehículo— está afecto a una actividad económica si se destina de forma exclusiva a la misma. Esta exigencia de exclusividad se matiza en el caso de los vehículos mixtos destinados al transporte de mercancías. En estos supuestos, se admite que puedan tener usos privados siempre que estos sean accesorios y de escasa relevancia.
El problema interpretativo: ¿Qué se entiende por «mercancías»?
La cuestión objeto de controversia gira en torno a si los vehículos utilizados por profesionales como fontaneros o albañiles para transportar herramientas, ropa laboral y otros materiales de trabajo pueden entenderse como “vehículos mixtos destinados al transporte de mercancías”. La resolución de esta duda tiene implicaciones directas en la posibilidad de deducir los gastos relacionados con dicho vehículo en el marco de una actividad económica.
Doctrina tradicional de la Administración tributaria
Tradicionalmente, la Administración tributaria ha mantenido una interpretación literal del concepto “mercancías”. Según este enfoque, solo los profesionales que transportan productos o bienes con destino al consumidor —como fruteros con fruta o pescaderos con pescado— podían considerar sus vehículos mixtos como afectos a la actividad. Así, el transporte de herramientas o enseres de trabajo no se consideraba incluido en esta categoría.
Cambio de criterio: ampliación del concepto de mercancía
El Tribunal Económico-Administrativo Central (TEAC) rompe con esta visión restrictiva y sostiene que, en atención al espíritu y finalidad de la norma, los vehículos mixtos empleados por profesionales como fontaneros o albañiles también deben considerarse afectos a la actividad, aunque se utilicen para transportar útiles de trabajo y no mercancías en sentido estricto.
Criterio actualizado del TEAC: presunción de afectación
El nuevo criterio adoptado por el TEAC en su Resolución 4214/2024, de 24 de junio de 2025, establece que si un vehículo mixto presenta características físicas (como la carrocería o la rotulación exterior) que evidencien su dedicación a la actividad profesional de su titular, debe presumirse su afectación a dicha actividad. Esta presunción puede ser desvirtuada por la Administración solo si acredita que el vehículo se emplea principalmente para fines particulares.
Consulta o descarga la resolución aquí
Haz clic aquí para descargar la resolución del TEAC 4214/2024, de 24 de junio de 2025
En resumen…
La interpretación del concepto de “vehículo mixto destinado al transporte de mercancías” se amplía gracias a la doctrina del TEAC, que permite incluir a los profesionales que trasladan materiales, herramientas y vestuario laboral como fontaneros o albañiles. La resolución elimina una barrera interpretativa que impedía la deducción de gastos, reforzando la seguridad jurídica de pequeños empresarios y autónomos en el uso profesional de sus vehículos. La clave estará en que estos vehículos presenten una apariencia clara de uso profesional, sin un uso privado relevante.
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