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V1968-25 16 October 2025 · SG de Impuestos Patrimoniales, Tasas y Precios Públicos Criterion in force
ITPAJD · agrupación de fincas

Group of properties taxed under variable AJD rate with reference value as base

The DGT confirms that a group of two adjacent properties with a single cadastral reference is subject to the variable rate of Documented Legal Acts, with the cadastral reference value serving as the taxable base.

The question raised

Tax base of the grouping of estates.

The DGT's ruling

The grouping of estates does not constitute a transfer, but rather a physical modification that is taxed under the variable rate of Stamp Duty if the requirements of Article 31.2 of the TRLITPAJD are met. The tax base shall consist of the value of the grouped estates pursuant to Article 70 of the RITPAJD. Since these are real estate properties with a reference value, this value shall constitute the tax base, unless the declared value or the agreed price is higher.

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