How the DGT's position has evolved
Current position
The novation, subrogation, or substitution of a loan does not exhaust the right to the deduction for the acquisition of a primary residence, provided that the new loan is used to amortize the previous one. Cancellation expenses and the installments of the new loan are deductible in the proportional part attributable to the original loan. The part of the new principal intended for purposes other than the acquisition or renovation of the dwelling is not deductible.
The DGT's position remains constant regarding the continuity of the deduction in loan novation or substitution operations. The rulings of 2022, 2024, and 2025 reiterate that the right persists as long as the new credit amortizes the previous one and deductibility is limited to the proportional part intended for the dwelling. No changes in criterion are observed in this area.
Analysis based on 58 of 63 rulings with a stated position. Updated 16 September 2026.