How the DGT's position has evolved
Current position
The accelerated depreciation of tangible fixed assets and real estate investments is a non-mandatory option that allows for the application of up to twice the maximum straight-line coefficient. This option must be exercised within the regulatory period for the tax return and does not allow for subsequent rectification. For the deduction for investment of profits, the properties must be new elements, understood as those that have not been previously used by any transferring entity.
The DGT's position remains constant in the application of commercial regulations for the valuation and write-off of real estate investments. No significant doctrinal changes are observed in the sequence, maintaining the requirement that elements must be new to access specific incentives and the optional nature of accelerated depreciation.
Analysis based on 26 of 31 rulings with a stated position. Updated 24 September 2026.