How the DGT's position has evolved
Current position
The transfer value is determined by the actual amount of the disposal, from which the inherent expenses and taxes paid by the transferor are deducted. These expenses include, among others, real estate agency fees, notary, registry, management, appraisal, and transfer taxes. In the case of acquisition, the value is composed of the actual amount, investments, improvements, and inherent expenses, excluding interest.
The DGT's position remains constant in defining inherent expenses as those directly related to the purchase or sale of the property. Throughout the rulings, consistency has been maintained by including mediation, notary, and registry expenses in both acquisition and transfer. No changes in criterion are observed, but rather a uniform application of the concept to different scenarios such as self-promotion or inheritances.
Analysis based on 41 of 42 rulings with a stated position. Updated 16 September 2026.