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Priority farming: 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 12 rulings · 2015–2021

Current position

The status of priority farming is proven through certification from the Autonomous Community or inclusion in the General Catalogue. To apply tax reductions, such as the 25% reduction in net income, it is essential to maintain the status of young farmer (under 40 years of age) and prove the implementation of an improvement plan. In transfers of farms with reduction, the acquirer must avoid disposal, leasing, or assignment for five years to preserve the benefit.

The DGT's position remains constant in the application of the requirements of Law 19/1995. Consultations have focused on specifying the mechanisms for proving the status of priority farming and delimiting the scenarios for the loss of tax benefits, such as reaching the age limit for young farmers or the transfer of farms before the legal period.

Turning points

  1. V3041-20

    Specifies that the right to the 25% reduction is lost in the year the farmer turns forty, upon ceasing to meet the condition of being a young farmer.

Analysis based on 8 of 12 rulings with a stated position. Updated 27 September 2026.

Rulings on this topic

12
V4047-16 22 Sept 2016

25% reduction in net income possible for young farmers

SG de Impuestos sobre la Renta de las Personas Físicas
estimación objetivarendimiento netoagricultor jovenexplotación prioritariaplan de mejora LIRPF — Ley 35/2006 del IRPF art. DA 6ª
Affects CompanyExpat · Non-residentIndividual

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