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Payment in Kind: 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 30 rulings · 2014–2025

Current position

In land-for-future-construction swaps, the delivery of the plot constitutes a payment in kind towards the building. VAT (IVA) is accrued at the moment the land is made available to the acquirer. This operation is subject to the tax if the land is a development plot or is urbanized and is considered the first delivery by the developer.

The DGT's position has remained constant over time. Rulings confirm that the delivery of land in swaps acts as an advance payment in kind, with the tax accruing when the land is made available to the acquirer. Likewise, the criterion is maintained that the resolution of these operations requires a rectification via invoice and not a new delivery.

Analysis based on 27 of 30 rulings with a stated position. Updated 24 September 2026.

Rulings on this topic

24

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