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Acquisition Cost: 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 41 rulings · 2014–2025

Current position

The deductible depreciation of real estate is calculated by applying 3% to the higher of two values: the acquisition cost paid (including expenses and taxes) or the cadastral value, always excluding the land value in both cases. If the land value is unknown, the acquisition cost must be prorated between the cadastral values of the land and the construction. The limit for accumulated depreciation is the acquisition value of the real estate excluding the land.

The DGT's position remains constant regarding the calculation of real estate depreciation. Since 2018, the doctrine has reiterated the application of 3% on the higher of the acquisition cost paid (excluding land) or the cadastral value (excluding land). The most recent rulings simply confirm and specify the proration mechanism in the event that the land value is unknown.

Turning points

  1. V1866-18

    Establishes the rule of applying 3% to the higher of the acquisition cost paid (including expenses and taxes, excluding land) or the cadastral value (excluding land).

  2. V1903-21

    Specifies that the applicable cadastral value is the one in force on the tax accrual date and sets the limit for accumulated depreciation at the acquisition value excluding the land.

Analysis based on 39 of 41 rulings with a stated position. Updated 23 September 2026.

Rulings on this topic

24
V2476-25 12 Dec 2025

Amortisation calculation differs for full ownership and usufruct

SG de Impuestos sobre la Renta de las Personas Físicas
rendimientos del capital inmobiliarioamortizaciónusufructo vitalicioplena propiedadvalor catastral LIRPF — Ley 35/2006 del IRPF art. 21LIRPF — Ley 35/2006 del IRPF art. 22
Affects CompanyExpat · Non-residentIndividual

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