Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The imputation of income for the non-built portion of rural properties with constructions that are not indispensable for exploitation is not applicable. In the case of indispensable constructions, there is also no imputation if they are not assigned to economic activities. Imputation is calculated based on the cadastral value of the construction plus the proportional part of the land. No income is imputed for properties under construction or those that, for urban planning reasons, are not susceptible to use.
The DGT's position remains stable regarding the exclusion of the non-built plot from the imputation of income. Throughout the rulings, specific cases of exclusion have been clarified, such as occupation by third parties through judicial proceedings or the impossibility of use for urban planning reasons. The distinction between constructions that are indispensable and those that are not indispensable for exploitation remains the core of the criterion.
Turning points
Establishes that the exclusion of income imputation applies when the land with construction is occupied by third parties against the owner's will, from the start of the judicial recovery procedure.
Introduces the impossibility of imputing income for properties under construction or those that, for urban planning reasons, are not susceptible to use, provided that such condition is proven.
Analysis based on 9 of 9 rulings with a stated position. Updated 29 September 2026.