Investment approach
Comprobación de valores: when Hacienda disputes your purchase price
The tax authority can check whether a property's declared value was understated and assess extra tax plus late-payment interest. How the mechanism works and how to remove the risk before you sign the arras.
Comprobación de valores is the Catalan tax administration's right to check whether a property's declared value is below market value and, if it is, to assess the extra ITP plus late-payment interest. Since the valor de referencia catastral was introduced in 2022, the check has become almost automatic: if the declared tax base is below the official benchmark, the difference becomes liable to extra tax without anyone having to value the individual deal. There is only one defence: find out the official figure before signing the arras (the deposit contract) and calculate the tax on it.
The right to check is not a formality
In the past, every discrepancy required a separate expert valuation. Now the benchmark is published in advance, and comparing a price against it needs no decision by an inspector. The tax administration sets out its method in its annual Instrucción de comprobación de valores.
What happens when extra tax is assessed
If the tax inspectorate considers the ITP base too low, the buyer receives a demand for the difference in tax plus late-payment interest. Where there are signs that the price in the documents was deliberately understated, penalties on top of the tax are possible. The demand can be challenged, but it is the taxpayer, not the tax authority, who has to prove market value.
How to avoid it in advance
Request the valor de referencia for the property, using its cadastral reference, before signing the arras. Once the official figure is known, the tax can be calculated precisely and in advance rather than from the listing price, which removes most of the risk. How the benchmark itself is set is explained in our article on the valor de referencia catastral.
Where it sits in due diligence
When DNPI Capital checks a property before a deal, requesting the tax base is mandatory, not optional: it affects the final project budget as much as the condition of the building does. The overall review process is set out in the legal due diligence section.
Questions and answers
Is every deal checked, or only a sample?
The comparison with the valor de referencia happens for every deal when the tax return is filed: the discrepancy is flagged by the system, not by an inspector who has decided to look at you in particular.
Can the assessment be challenged?
Yes, but you will usually need an independent expert valuation of the property supporting a lower market value. Without one, arguing against the official benchmark is difficult in practice.