Modelo 210 Guide
Cadastral Value vs. Reference Value: Which Figure Counts for Modelo 210, ITP and Inheritance Tax?
Valor catastral, Valor de Referencia and market value explained: which property value applies to Modelo 210, ITP and inheritance tax — including the 2026 Constitutional Court ruling and how to challenge it.
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Valor Catastral, Valor de Referencia, or Market Value — The Short Answer
In Spain there are three property values that are frequently confused: the Valor catastral, the Valor de Referencia, and the market value. For imputed income (Renta imputada) on own-use or vacant properties under Modelo 210, the Valor catastral applies. For purchases, inheritance, and gifts, the Valor de Referencia plays the central role instead. For rental income or a sale, different taxable bases apply again.
In short: not every Spanish property value is relevant for every tax. This confusion is one of the most common mistakes among non-residents with Spanish property.
The Three Values at a Glance
| Value | What it applies to | Who sets it | Updated |
|---|---|---|---|
| Valor catastral | IBI (local property tax), Modelo 210 — imputed income for own use/vacant property | Catastro, via municipal valuation rolls (Ponencias de Valores) | Rarely, often stable for years |
| Valor de Referencia | ITP, ISD (inheritance/gift tax) for property — generally the applicable minimum, unless the declared value or purchase price is higher | Dirección General del Catastro, based on notarised sale prices | Annually, elements published before 30 October |
| Market value | Benchmark for valuations and challenges; relevant where no Valor de Referencia exists or cannot be certified | Market forces, potentially confirmed by a professional valuation | Ongoing |
Valor Catastral — The Figure for Imputed Income
The Valor catastral is the official, historically established value of a property, shown on the annual IBI bill. It is set via municipal valuation procedures (Ponencias de Valores) and updates considerably more slowly than actual market value — in many municipalities it has remained unchanged for years and sits well below the real property value.
The Valor catastral applies to imputed income (Renta imputada) for own use or vacant properties:
- For own use: Renta imputada = Valor catastral × factor (1.1% or 2.0%) × tax rate
- The Valor de Referencia or the actual purchase price play no role in this calculation
Important: Modelo 210 also covers rental income and capital gains, in addition to imputed income — different taxable bases apply there: actual rental income for lettings, or the capital gain (the difference between sale value and acquisition value) on a sale.
Valor de Referencia — The Figure for Purchase, Inheritance and Gifts
The Valor de Referencia was introduced in 2022 and is determined annually by the Dirección General del Catastro based on all notarised sale prices in the relevant area. It generally serves as the applicable minimum taxable base for transfer tax (ITP) and inheritance/gift tax (ISD).
Key mechanic: if the declared value is below the Valor de Referencia, the reference value applies. If it is above, the declared value applies.
In Spain, this is colloquially — and critically — referred to as "el catastrazo", since it can lead to unexpectedly high tax bills in practice when the official reference value exceeds the actual sale price.
By law, the Valor de Referencia may not exceed market value. To help ensure this, a statutory reduction factor is applied — under Orden HFP/1104/2021, this is generally 0.9 for urban and rustic properties.
Publication: the valuation basis is published before 30 October, with individual property values usually following in December. They apply for the relevant tax year from 1 January and can be checked via the Sede Electrónica del Catastro.
Recent Legal Development: 2026 Constitutional Court Ruling
In ruling STC 13/2026, Spain's Constitutional Court broadly upheld the Valor de Referencia system. What mattered was that the reference value is not designed as an unchallengeable figure, but can be contested by the taxpayer through the available legal remedies. The Valor de Referencia is therefore not a final, case-by-case market valuation, but a statutory valuation figure that can be corrected.
Open legal question: on 29 April 2026, Spain's Supreme Court (Tribunal Supremo) admitted an appeal for review (Recurso 8442/2024) — not yet decided — intended to clarify what specific evidentiary requirements a valuation report must meet to successfully challenge the Valor de Referencia. Until this ruling, the practice around evidencing a challenge is not fully settled.
How Can the Valor de Referencia Be Challenged?
Standard, lower-risk route — declare based on the Valor de Referencia and request a correction: you initially declare based on the Valor de Referencia, then apply for a correction of your self-assessment (rectificación de autoliquidación), supported by appropriate evidence. This route avoids late-payment interest and surcharges while the request is reviewed.
Higher-risk route — declare a lower value and challenge a subsequent assessment: if you declare only the lower purchase price directly, expect the tax authority to issue a supplementary assessment with late-payment interest — and, in an unfavourable case, penalties as well. This route should only be taken after tax advice.
On evidence: a qualified professional valuation report is usually the most persuasive evidence in practice — documenting the property's condition, location, defects, or other value-reducing factors. Listing prices from property portals alone generally do not suffice. The specific evidentiary requirements are not yet finally settled at the highest court level, pending the ongoing Supreme Court proceedings.
What This Means in Practice for Owners
- For imputed income under your annual Modelo 210, you need the Valor catastral — found on your IBI bill
- When buying property, check the Valor de Referencia via the Sede Electrónica del Catastro in advance to avoid supplementary assessments
- For inheritance or gifts, the Valor de Referencia is also relevant for the ISD taxable base, unless a higher declared value applies
- If the reference value diverges significantly from your property's actual condition, a challenge supported by a solid valuation report is possible — the chances of success depend on the quality of the evidence
What We See in Practice
At Fiscaro, we regularly observe two patterns:
Confusing the three values: owners frequently use the Valor de Referencia or the purchase price for the imputed-income calculation, when only the Valor catastral is relevant — leading to incorrect tax calculations in either direction.
Unexpected supplementary assessments on purchase: buyers agree a price below the Valor de Referencia applicable for the year of acquisition and are then surprised by a supplementary assessment, having not checked the reference value before signing.
How High Is Your Annual Modelo 210 Tax? Calculate Now
You only need the Valor catastral from your IBI bill to calculate this. Our calculator gives you a quick estimate.
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Common Mistakes
- Using the Valor de Referencia for imputed income — only the Valor catastral applies here
- Not checking the Valor de Referencia before completing a purchase — leads to unexpected ITP assessments
- Attempting a challenge without solid evidence — listing prices from property portals alone generally do not suffice
- Assuming an outdated Valor catastral — the value can change following municipal revaluations (Ponencias de Valores)
FAQ
Why is my cadastral value so much lower than my property's market value? The Valor catastral is based on municipal valuation procedures (Ponencias de Valores), which are updated far less frequently than the property market moves. In many municipalities the value has remained unchanged for years and therefore sits below actual market value.
Do I need to use the Valor de Referencia for Modelo 210? No, not for imputed income on own use or vacant properties — only the Valor catastral applies there. For rental income or a sale under Modelo 210, different taxable bases apply.
Where can I find my property's Valor de Referencia? Via the Sede Electrónica del Catastro, using the 20-character Referencia Catastral. Values for the relevant year are available from January.
Can I challenge an excessive Valor de Referencia? Yes. In 2026, the Constitutional Court confirmed that the Valor de Referencia is a rebuttable presumption. A qualified professional valuation report can often be used to evidence a lower, actual value — the exact evidentiary requirements are still being clarified at the highest court level.
Does the Valor catastral automatically change with market value? No. It is only adjusted through municipal revaluation procedures, which occur irregularly and with a considerable time lag.
Sources
- Real Decreto Legislativo 1/2004 (Spanish Cadastre Act)
- Ley 11/2021 (introduction of the Valor de Referencia)
- Orden HFP/1104/2021 (reduction factor of 0.9)
- Constitutional Court, ruling STC 13/2026 (February 2026)
- Supreme Court, order of 29.04.2026 (Recurso 8442/2024) — appeal admitted, not yet decided
- Dirección General del Catastro: Valores de Referencia
Conclusion
Spain's three property values — Valor catastral, Valor de Referencia, and market value — serve different tax purposes and should not be confused. For imputed income under your annual Modelo 210, the Valor catastral from your IBI bill applies. When buying or inheriting property, however, it's worth checking the Valor de Referencia in good time to avoid unexpected supplementary assessments.
Fiscaro guides you through the relevant cadastral data when filing Modelo 210 and uses the Valor catastral for the imputed-income calculation.

Hanns-Christopher Deppe
Founder of Fiscaro · Real Estate Economist & Dipl. Industrial Engineer · Agent in Mallorca
Hanns-Christopher has lived in Mallorca for over 15 years and has guided hundreds of non-residents through their Spanish tax obligations. He founded Fiscaro to make the Modelo 210 process as simple as possible.
This article is for general information purposes only and does not constitute individual tax advice. For an assessment tailored to your specific circumstances, we recommend consulting a qualified tax adviser or Spanish gestoría.
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