How the DGT's position has evolved
Current position
Wealth variations occur due to any increase or decrease in the value of assets, as happens with the receipt of subsidies, grants, or indemnities. These variations are included in the general taxable base as they do not derive from a transfer of assets. In the case of losses due to fraud, these are only deductible if they are not unjustified and are proven with evidence admitted under Law.
The DGT's position remains constant in defining wealth variation as any alteration in the value of assets. Throughout the rulings, the inclusion in the general base for concepts not linked to transfers has been maintained. Recent doctrine adds the need to prove the loss in cases of fraud to avoid its characterization as unjustified.
Turning points
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Establishes that loss due to fraud requires proving that it is not unjustified through evidence admitted under Law to have an impact on the IRPF (Personal Income Tax).
Analysis based on 49 of 50 rulings with a stated position. Updated 20 September 2026.