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Plot: 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 8 rulings · 2014–2025

Current position

Storage rooms and parking spaces (maximum of two) are taxed at the reduced rate of 10% if they are transferred together with the dwelling and are located on the same plot or real estate complex as the building and its common areas. If these elements are located on different plots or in different buildings, they will be taxed at the general rate of 21%. The exemption for those over 65 years of age only applies to the dwelling and the part of the plot that serves it.

The DGT's position remains constant regarding the need for physical and plot-based linkage to apply the reduced 10% rate to garages and storage rooms. The idea that location on the same plot is the determining factor to avoid the general rate has been reinforced. No changes in criterion are observed, but rather a reiteration of the requirements of simultaneity and location.

Turning points

  1. V2210-21

    Clarifies that the transfer of a plot is an operation independent of the construction of the dwelling, taxed at 21% for not being a single operation.

  2. V2892-21

    Establishes that the VAT (IVA) treatment is the same for garages even if they are registered as independent plots, provided they are on the same physical plot.

Analysis based on 8 of 8 rulings with a stated position. Updated 13 October 2026.

Rulings on this topic

8
V2210-21 31 Jul 2021

VAT on the delivery of a plot for residential construction is 21%

SG de Impuestos sobre el Consumo
tipo impositivoentrega de bienesejecución de obrasautopromocióntipo reducido LIVA — Ley 37/1992 del IVA art. 90.UnoLIVA — Ley 37/1992 del IVA art. 91.Uno.1.7º
Affects CompanyExpat · Non-residentIndividual

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