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V2025-20 19 June 2020 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · imputación de rentas inmobiliarias

No imputed real estate income for unbuilt land on plots with buildings not used for business activities

A query was raised regarding whether real estate income should be imputed for an industrial plot containing trees and a small warehouse not used for economic activity. The DGT ruled that unbuilt land does not generate imputed income, whereas buildings do.

The question raised

Whether the imputation of real estate income would proceed and, if so, whether it would be for the entirety of the property or only for the built portion.

The DGT's ruling

In urban or rural properties with constructions that are not indispensable for operations, the imputation of income is not applicable to the unbuilt portion of the plot. For the building, the calculation base shall be the cadastral value of the construction plus the proportional part of the land corresponding to it.

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