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Net Book Value: 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 · 2015–2023

Current position

The net book value for determining capital gains or losses must be adjusted by replacing accounting depreciation with tax-deductible depreciation. This criterion applies to both the transfer of real estate and the extinction of investments in tangible fixed assets. In the case of vessels under special regimes, the calculation integrates the unavailable reserve and the difference between the transfer value and the tax value.

The DGT's position remains constant in applying the net book value adjusted by tax depreciation to determine capital results. No changes in calculation methodology are observed, but rather an application of the same criterion to different assets such as livestock, real estate, or vessels. The doctrine is uniform regarding the need to replace accounting depreciation with tax-deductible depreciation.

Analysis based on 8 of 8 rulings with a stated position. Updated 30 September 2026.

Rulings on this topic

8

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