How the DGT's position has evolved
Current position
The exemption under Article 20.One.20º of Law 37/1992 applies to the transfer of rural land as long as it is not undergoing urbanization. The urbanization process is only considered to have started when material works for the provision of infrastructure, such as access, water, or energy, are executed. Administrative procedures or preliminary studies are not sufficient to cause the land to lose its rural nature.
The DGT's position remains constant throughout the analyzed sequence. From 2019 to 2026, the criterion requires the execution of material works of physical transformation or the assumption of infrastructure costs to consider land to be undergoing urbanization. There is no doctrinal variation in the distinction between administrative procedures and material actions.
Analysis based on 6 of 8 rulings with a stated position. Updated 13 October 2026.