Doctrine by topic · DGT Observatory

Fungible Nature of Money: 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

Settled doctrine High confidence 21 rulings · 2015–2023

Current position

The exemption for reinvestment requires that the amount invested in the new home be equivalent to the amount obtained from the transfer of the old one within a period of two years, either before or after. Due to the fungible nature of money, identity between the funds obtained from the sale and those used for the purchase is not required. The sale amount may serve to replenish previously invested savings or to amortize the mortgage debt of the new home.

The position of the DGT remains constant across all analyzed rulings. The criterion establishes that the fungible nature of money allows the sale funds not to coincide with those of the purchase, provided that savings are replenished or the debt is amortized. No changes or nuances in the applied doctrine have been observed from 2015 to 2023.

Analysis based on 20 of 21 rulings with a stated position. Updated 25 September 2026.

Rulings on this topic

21
V1952-23 5 Jul 2023

The exemption for reinvestment is not applicable if the new dwelling was acquired outside the two-year period prior to the sale (considering the suspension of deadlines due to COVID-19)

SG de Impuestos sobre la Renta de las Personas Físicas
exención por reinversiónvivienda habitualganancia patrimonialtransmisión de inmueblessuspensión de plazos LIRPF — Ley 35/2006 del IRPF art. 38.1RIRPF — RD 439/2007, Reglamento del IRPF art. 41
Affects CompanyExpat · Non-residentIndividual

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