How the DGT's position has evolved
Current position
Deductible depreciation in income from real estate capital cannot exceed 3% of the higher of the acquisition cost paid or the cadastral value, always excluding the land value in both cases. If the land value is unknown, it must be calculated by prorating the acquisition cost between the cadastral values of the land and the construction. This criterion applies individually even in properties acquired jointly.
The DGT's position has remained constant since 2017. The rulings repeatedly confirm the exclusion of the land value for the calculation of depreciation and the proration method based on cadastral values when this value is unknown. No changes in the applied doctrine are observed.
Analysis based on 17 of 17 rulings with a stated position. Updated 25 September 2026.