How the DGT's position has evolved
Current position
The acquisition value in transfers by way of gratuitous title is the one resulting from applying the rules of the Inheritance and Gift Tax, without exceeding the market value. To this amount, investments, improvements, expenses (notary, registry, management fees) and taxes inherent to the acquisition paid by the acquirer must be added. The acquisition date is backdated to the moment of the deceased's death.
The DGT's position remains constant in determining the acquisition value for Personal Income Tax (IRPF) in transfers by way of gratuitous title. The rulings confirm that this value integrates the amount resulting from the inheritance tax, the market value, and the expenses or taxes inherent to the acquisition. No changes in criterion are observed, but rather a reiteration of the composition of said value.
Turning points
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Specifies that investments, improvements, expenses, and taxes must be added to the acquisition value, including the Inheritance and Gift Tax of the parent property.
Analysis based on 51 of 55 rulings with a stated position. Updated 19 September 2026.