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V2893-18 8 November 2018 · SG de Impuestos sobre el Consumo Criterion in force
IVA · derechos de pago único

Transfer of single payment rights alongside rural property follows the land's tax regime if ancillary

The applicant asks how to determine the tax base when purchasing rural property together with the seller's single payment rights. The DGT rules that if the transfer of rights is ancillary to the transfer of the property, it will follow the same tax regime as the land.

The question raised

Determination of the taxable base corresponding to the consulted operation.

The DGT's ruling

If the assignment of single-payment rights accompanies the assignment of eligible hectares, it is considered an ancillary supply that follows the tax regime of the principal operation (the land). Therefore, if the rural estate is exempt pursuant to Article 20.one.20º of Law 37/1992, the rights shall also be exempt. The taxable base shall be the consideration fixed for the operation at the time of accrual.

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