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A query was raised regarding when the capital gain or loss resulting from the compulsory expropriation of a property should be temporally attributed. The DGT ruled that the change in assets occurs when the fair price is determined and paid, and the asset is subsequently occupied.
Question raised: Temporal imputation.
Compulsory expropriation generates capital gains or losses, as do any late payment interest received. Except in urgency procedures, the change in assets occurs when the fair price is determined and paid and the occupation of the expropriated property takes place. The temporal imputation must be made in the tax period in which said change occurs.
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