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V2562-17 10 October 2017 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · imputación de rentas

No income imputation for unbuilt land in urban plots not used for economic activity

A query was raised regarding whether income should be imputed for the entirety of an urban plot containing small buildings or only for the built area. The Directorate General for Taxes (DGT) ruled that income imputation is not applicable to the unbuilt portion of the land.

The question raised

Whether the imputation of income would proceed for the entirety of the land or only for the built part, and in the latter case, the calculation base.

The DGT's ruling

In urban real estate not used for economic activities nor generating income from capital, unbuilt land is excluded from the imputation of income. The calculation base for the building shall be the cadastral value of the construction plus the proportional part of the land corresponding to it.

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