How the DGT's position has evolved
Current position
The ownership proceeding or deed of notoriety constitutes an onerous transfer of assets subject to ITPAJD (Transfer Tax and Stamp Duty). Liability is avoided only if the promoter proves they have satisfied the tax or the exemption for the transfer whose title is being replaced. The taxable event arises upon the formalization or issuance of the supplementary title.
The DGT's position has remained constant since 2014. All rulings confirm that the ownership proceeding is a taxable event for onerous transfers of assets, unless prior payment of the transfer being replaced is proven. No changes have been observed in the nature of the taxable event or its accrual.
Analysis based on 24 of 25 rulings with a stated position. Updated 24 September 2026.