How the DGT's position has evolved
Current position
The transfer of urban land or land undergoing urbanization is subject to IVA (Value Added Tax) at the general rate. The exemption for land only applies to rural or non-buildable land. If, in order for urbanized land to become buildable again, a new urbanization process is required whose material works have not yet begun, the transfer shall be subject but exempt according to article 20.Uno.22º of the IVA Law.
The DGT's position remains constant regarding the subject to IVA of urban and developable land, differentiating them from rural land. The evolution shows technical precision regarding the state of urbanization and the commencement of material works to determine the application of specific exemptions.
Turning points
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Introduces the possibility of applying the exemption of article 20.Uno.22º if urbanized land requires a new urbanization process whose material works have not yet begun.
Analysis based on 13 of 13 rulings with a stated position. Updated 27 September 2026.