How the DGT's position has evolved
Current position
The supply of rural land is exempt from IVA (Value Added Tax) provided that it is neither buildable nor undergoing urbanization. It is considered to be undergoing urbanization when physical transformation works have commenced or the transferor has incurred urbanization costs. If the land is a building plot or buildable, the exemption does not apply. The purchaser with the right to deduction may waive the exemption.
The DGT's position remains constant regarding the application of the exemption for non-buildable rural land. The evolution focuses on refining the concept of 'undergoing urbanization', requiring the execution of material infrastructure works or the assumption of physical transformation costs for the transaction to become taxable.
Turning points
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Defines that land is undergoing urbanization from the moment the execution of infrastructure provision works begins.
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Clarifies that urbanization requires the material provision of infrastructure such as access, water, or energy, and not just administrative procedures.
Analysis based on 37 of 37 rulings with a stated position. Updated 23 September 2026.