The Andalusian Parliament approved the 2026 Regional Budget (Ley 8/2025) on December 22, 2025, with publication in the BOJA on December 31, 2025. This legislation introduces targeted changes to fiscal rules, most notably a reform to the reduced 2% Property Transfer Tax (ITP) rate under Article 44. This rate previously benefited professional real estate operators (individuals or companies engaged in property development, buying/selling, or similar activities aligned with sector accounting rules) purchasing homes explicitly for resale.The changes aim to curb speculative use of the incentive while supporting faster market turnover for qualifying properties. They have taken effect from January 1, 2026.

Key changes to the 2% reduced ITP rate for resale properties

• New Value Threshold: The reduced 2% ITP now applies only if the combined value of the property (including full ownership rights) and any annexes (e.g., garages, storage rooms) does not exceed €500,000. Properties valued above this limit (based on the declared acquisition value or 100% of full domain) revert to the standard ITP rate of 7% (payable by the buyer on resale/second-hand properties).
• Shorter Resale Period: The timeframe to resell the property and retain the tax benefit has been reduced from 5 years to 2 years. The resale must be formalized via public deed (with possession transferred) within this 24-month window following the initial acquisition.

These requirements include:

• The buyer must be a professional operator (evidenced by relevant IAE registration and incorporation into circulating assets).
• The intention to resell must be expressly stated in the public deed.
• The resale must also be subject to (and not exempt from) ITP.
  
  

When do these changes apply?

• Purchases completed on or before December 31, 2025, follow the old rules: no value cap and a 5-year resale window.
• From January 1, 2026, all new qualifying acquisitions are subject to the updated limits.

Market impact for property investors
This reform significantly affects "flipping" strategies, particularly in premium coastal areas like Marbella, the Golden Mile, Puerto Banús, and broader Costa del Sol markets, where many professional deals involve properties well above €500,000.

• Higher Upfront Costs — For assets exceeding €500,000, buyers face an immediate 5% increase in transfer tax (from 2% to 7%), reducing potential margins on resale.
• Tighter Timelines — The compressed 2-year exit window demands faster execution, leaving less buffer for refurbishments, repositioning, construction delays, or market downturns.
• Strategic Shifts — Investors may pivot toward smaller or mid-range properties (under €500,000 total value) to retain the tax advantage, or accept higher taxes on luxury/high-value deals. Quick-turnaround projects in more affordable segments could see continued support, while larger luxury flips require recalibrated economics.
  
  
  

Overall, while the 2% incentive remains available for eligible mid-market operations, the reform tightens conditions to promote efficient, professional activity rather than long-term holding or speculation. Property investors, especially those active in high-end Andalusian markets should review ongoing and planned deals, consult tax advisors, and adjust models accordingly to navigate the new landscape effectively.