How the DGT's position has evolved
Current position
The substitution or novation of a loan does not exhaust the right to the deduction for investment in a primary residence, provided that the new loan is intended to amortize the previous one. The costs of appraisal, notary, and registry for the new operation are deductible. In the case of an increase in the principal, only the portion intended to cover the cancellation costs of the previous loan is deductible.
The DGT's position remains constant regarding the continuity of the deduction following the substitution of loans. The most recent rulings specify the deductibility of new expenses associated with the operation, such as appraisal or notary fees, provided that the purpose of amortizing the original debt is maintained.
Turning points
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Specifies that novation or substitution does not exhaust the deduction and establishes that the expenses of the new loan are deductible in proportion to the original loan.
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Extends deductibility to the appraisal, notary, and registry costs of the new operation when the loan substitution is carried out.
Analysis based on 539 of 568 rulings with a stated position. Updated 24 September 2026.