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Compensation Board: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 61 rulings · 2014–2026

Current position

The compensation board acts as the main contractor for urbanization works. The board members acquire the status of entrepreneurs upon receiving the first assessment that incorporates urbanization costs, provided there is an intention to sell the land. In this case, the transfer of the plots is subject to VAT instead of ITP.

The DGT's position remains constant in determining the status of an entrepreneur. It has been reaffirmed that the allocation of urbanization costs through assessments is the milestone that transforms the owner into an entrepreneur if there is an intention to sell. The doctrine has specified that participation in fiduciary boards requires an analysis of effective management to determine the economic activity.

Turning points

  1. V2960-18

    Establishes that the status of an entrepreneur is acquired by incorporating urbanization costs into the land through the payment of the first assessment, conditioned on the intention to sell.

  2. V1796-21

    Introduces the need to analyze effective management and the performance of prior or subsequent operations to determine whether participation in a fiduciary board constitutes an economic activity.

Analysis based on 58 of 61 rulings with a stated position. Updated 22 September 2026.

Rulings on this topic

24

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