Doctrine by topic · DGT Observatory

Fixed Asset: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Stable position Medium confidence 8 rulings · 2014–2021

Current position

The acquisition of used real estate is eligible for the Canary Islands Investment Reduction (RIC) if the asset is a tangible fixed asset used for economic activity, located and used in the Canary Islands. In small-scale entities, it may be considered an initial investment provided that the real estate has not previously benefited from the RIC. The classification of assets as fixed asset elements requires their use for an economic activity and prior registration in the Census of Entrepreneurs.

The DGT's position does not show a doctrinal evolution, but rather an application of specific criteria for different incentives and taxes. The rulings focus on the nature of the fixed asset for the RIC in the Canary Islands, its treatment in the Personal Income Tax (IRPF), and its classification as an element of economic activity. There is no change in criterion, but rather a thematic dispersion regarding the concept of fixed assets.

Analysis based on 7 of 8 rulings with a stated position. Updated 30 September 2026.

Rulings on this topic

8

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