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V2140-24 ·3 October 2024 ·consulta-vinculante Medium impact
Tax

Compensation fiduciary applies investment to unpaid urbanisation payments and charges IVA on land transfers

A Compensation Fiduciary receiving land from a debtor to settle unpaid urbanisation payments queries whether IVA applies to the acquisition and whether future payments should be subject to the passive investor rule under LIVA article 84.1.2.f. The DGT concludes that the transfer of land for debt repayment constitutes a goods delivery subject to IVA, with tax due upon transfer of disposal rights, and that urbanisation payments to compensation fiduciaries are subject to passive investor treatment under LIVA article 84.1.2.f.

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2024-10-03PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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