The specific real estate regime covers not only the purchase, sale, and rental of properties, but also construction services. However, the distinction between providing construction services and simply selling building materials has become legally relevant, and the 2026 regulations have made significant progress in clarifying this issue.

The regulations define construction services as the execution, under administration, general contracting, or subcontracting arrangements, of civil, hydraulic, or electrical construction works. This includes demolition, repair, maintenance, renovation, and the installation of goods that become permanently incorporated into the property. This is a functional concept that goes beyond the construction of new buildings.

On the other hand, the mere supply of materials used in construction, even when delivered directly to the construction site, does not constitute a construction service and remains subject to the general IBS and CBS rules, without the reduced tax rates provided under the specific regime. A building materials retailer, a cement manufacturer, or a window frame supplier does not become a construction service provider simply by delivering products to a construction site. What brings an operation under the specific regime is the actual execution of the construction work, not the sale of supplies.

This distinction has a direct impact on pricing. Companies that contract materials and labor separately may receive different tax treatment from those that hire an integrated service, such as a turnkey construction contract. It is therefore worth reviewing how construction contracts are structured ahead of the full implementation of the new tax rates.

The regulations also clarify that the mere provision of space, when ancillary to another main service, such as accommodation, parking, events, coworking, or healthcare services, is not treated as a real estate transaction. This rule prevents different business activities from being artificially reclassified as property rentals simply because they involve the temporary use of real estate.

Since construction projects are generally carried out in stages, with progress measurements and partial deliveries, the taxable event for IBS and CBS in construction services follows the general rules for continuous or split transactions. This allows taxes to be calculated according to the execution, measurement, or division of the service, rather than only at the beginning or completion of the project.

The entitlement to IBS and CBS tax credits on materials used in construction will depend on maintaining cost accounting organized by project or on identifying the construction project in the tax document itself. This traceability requirement brings the construction industry closer to a stricter project-based cost control system. Materials exceeding the permitted limit, or failing to meet these documentary requirements, will result in the reversal of the corresponding tax credits.

As a general rule under the specific regime, construction services benefit from a 50% reduction in the combined IBS and CBS tax rates. The same reduction applies to property purchases, sales, and real estate development, while a 70% reduction is reserved for property rentals and assignments of use.

Construction companies and real estate developers should review their contract structures and project-based accounting procedures in advance. Properly separating materials from services, documenting the allocation of supplies to each development, and adapting tax document issuance systems are no longer just good management practices. They have become essential requirements for correctly claiming tax credits under the new system.