Doctrine by topic · DGT Observatory

Participation Coefficients: 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 10 rulings · 2014–2023

Current position

The modification of horizontal property coefficients is not subject to the gradual rate of AJD (Stamp Duty) because it lacks an object with a valuable amount or thing. This criterion is maintained as long as the surface areas of the apartments or premises are not altered and the real value of the cost of the new construction plus the value of the land does not undergo changes. In the event that the modification results in an increase in surface area compared to the initial horizontal division declaration, it will be subject to the variable rate.

The DGT's position has remained constant since 2014. The administration has reiterated that the rectification of coefficients does not constitute a transfer nor a taxable event for the gradual rate of AJD if there is no alteration of surface areas or values. The doctrine has been consolidated through the distinction between the mere variation of quotas and the actual increase in surface area or value.

Analysis based on 9 of 10 rulings with a stated position. Updated 28 September 2026.

Rulings on this topic

10

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