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Improvements: evolution of DGT doctrine

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 35 rulings · 2014–2026

Current position

Repair and maintenance expenses intended to maintain useful life or capacity for use are deductible from the net income of real estate capital. Improvement or expansion works that increase capacity, habitability, or useful life are not deductible expenses, but must be integrated into the acquisition value of the property. For pre-rental expenses to be deductible, they must be directed exclusively toward the generation of income and not toward the owner's enjoyment.

The position of the DGT remains constant in the distinction between repair expenses and improvements. The rulings confirm that improvements increase the acquisition value, while repairs are deductible expenses. No changes in criterion are observed in the analyzed sequence.

Analysis based on 35 of 35 rulings with a stated position. Updated 23 September 2026.

Rulings on this topic

24
V1777-22 27 Jul 2022

Mortgage cancellation costs and home improvements increase acquisition value

SG de Impuestos sobre la Renta de las Personas Físicas
valor de adquisicióngastos inherentesmejorasreparaciones y conservaciónamortización de bienes muebles LIRPF — Ley 35/2006 del IRPF art. 23LIRPF — Ley 35/2006 del IRPF art. 27.2
Affects CompanyExpat · Non-residentIndividual

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