Investment approach
Catalonia's 20% ITP for a gran tenedor: who pays it and from when
From 27 June 2025, a large holder buying a home in Catalonia pays ITP at 20% instead of 10–13%. In Barcelona the status starts at just five flats, so check it before every purchase.
From 27 June 2025, a buyer of residential property in Catalonia who qualifies as a gran tenedor (large holder) pays ITP at 20% rather than on the usual 10–13% scale. In Barcelona you reach that status with as few as five flats, so an investor with even a small portfolio needs to check it before every purchase.
What Decret llei 5/2025 changed
The higher rate was introduced by Decret llei 5/2025 of 25 March 2025 (DOGC No. 9379): 20%, instead of the usual 10–13%, on home purchases by large holders (gran tenedor). According to the Agència Tributària de Catalunya (ATC), it applies to transactions from 27 June 2025.
Anyone buying an entire residential building pays the same 20%, even if they are not a gran tenedor. The exception is an individual buying a building with no more than four flats, provided every flat becomes the main home of the buyer or of relatives up to the second degree: they must move in within 12 months and live there for at least three years.
Who counts as a gran tenedor
A large holder is an individual or a company that owns more than ten residential properties in Catalonia, or more than 1,500 m² of residential floor space. There is a second test as well: five or more residential properties in municipalities designated as a zona de mercado residencial tensionado (an officially designated stressed housing market area), not counting garages and storage rooms. Barcelona is one of these areas, so here the threshold is effectively five flats.
Status is determined before the purchase: someone who owns four flats in such an area buys the fifth on the standard scale, and it is the next purchase that pays 20%. An individual's own main home is left out of the count. And if a gran tenedor buys a flat to live in permanently (for at least three years), the 20% rate does not apply either. The ATC sets out these rules on its ITP rates page.
If a storage room and up to two parking spaces are bought along with the flat, either at the same time or in the same building, they are taxed at the same 20%.
What getting the status wrong costs
Getting the status wrong doubles the tax. On a €600,000 property that is €60,000 against €120,000.
How the rate is applied is spelt out in Resolución 3/2025 of the Direcció General de Tributs i Joc (amended by Resolución 2/2026). How it applies to a particular buyer's structure has to be checked before every purchase: how your last purchase was treated is no guide.
How we account for this in DNPI projects
DNPI Capital sets up each project as a separate deal and does not build up a portfolio of dozens of properties inside one company. We check case by case whether the gran tenedor rate applies to a deal, at the due diligence stage and before the deposit is paid, not after. Our general checking process is set out in the legal due diligence section.
Questions and answers
Does the 20% rate apply only to companies, or to private investors too?
Private investors too. The gran tenedor definition applies equally to individuals and companies: what matters is how many properties you own and where they are, not how you hold them.
I own four flats in Madrid and I'm buying my first one in Barcelona. Am I a gran tenedor?
No, if you own nothing else. The 'more than ten properties' and 'more than 1,500 m²' tests count only homes in Catalonia. The 'five or more' test counts homes in municipalities designated as stressed housing market areas, and the ATC lists two such areas, both in Catalonia. Your Madrid flats fall outside every count. Even so, it is worth having a tax adviser confirm how this applies to your ownership structure.