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V2487-19 17 September 2019 · SG de Tributos Locales Criterion in force
OTRO · ibi

IBI statute of limitations depends on interrupting acts within four years of accrual

A property owner inquired whether the IBI for 2014 and 2015 had expired, given that the determination of cadastral values was notified years later. The DGT clarifies that cadastral proceedings involving knowledge of a co-owner interrupt the statute of limitations for all liable parties.

The question raised

Clarification regarding the possible statute of limitations for the IBI for the years 2014 and 2015, due to more than 4 years having elapsed from the date of accrual to the determination of the tax debt.

The DGT's ruling

The statute of limitations for the IBI to settle the debt begins on the date of accrual. Actions taken by the Administration or by an obligor with formal knowledge of any of the co-holders interrupt the period and restart the four-year calculation. If the only act with formal knowledge was the notification in August 2018, the 2014 IBI would be time-barred, but the 2015 IBI would not be.

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