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V0431-26 27 February 2026 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · atribución de rentas

Land purchases not deductible, but personnel costs can be

A civil society running livestock farming asks whether it can deduct land purchases for planting and personnel costs. The DGT responds that land is a patrimonial element and not a deductible expense or amortizable, whereas personnel costs are deductible under certain conditions.

The question raised

Question posed: Whether the expense for the purchase of said estates would be deductible for Personal Income Tax purposes. Furthermore, it is asked whether, in the event that personnel are hired for the aforementioned planting, the expenses incurred would be deductible.

The DGT's ruling

The purchase of land is not a deductible expense as it constitutes assets used in the activity, and land is not subject to depreciation. Personnel recruitment expenses are deductible if the direct estimation method is used, provided they are linked to the activity, justified, and recorded. If the objective estimation method is used, these expenses do not affect the calculation of net income.

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