Division 4.1 The reports

As can be seen, Euroval has not signed nor stamped any of these reports, i.e. there is no evidence at all that the entity takes responsibility for the valuations.

The Spanish authorities state that the valuation reports on the land drawn up in 2000 and 2002 do not fulfil the requirements of Ministerial Order ECO 805/2003 regarding the valuation of buildings, ‘since their purpose is other than the scope of application of that Order’ (e.g. p. 3 of the report providing the 2000 valuation for office space). It is not explained why the aforementioned ministerial order should not apply. The aforementioned ministerial order is also mentioned in conjunction with Law 6/1998 on land valuation (p. 13 of the aforementioned report). It is argued that, since it is a retrospective valuation for the year 2000 made in 2002, ‘the acting technical team is free to apply the calculation adjustments and hypotheses it considers most appropriate for the objective pursued.’ However, the ‘adjustments’ and ‘hypotheses’ are not spelled out. Furthermore, it is not clear why existing law can not be applied, particularly with regard to the valuation of the land. Nor is a justification provided for not applying the laws that were in force at the time.

The report providing the current (2009) valuation of the plot destined for office blocks contains an even more surprising statement. It is claimed that the valuation methods applicable according to the current legislation in force can be adapted because: ‘since the purpose of the valuation is a non-monetary contribution at the date in question, the acting technical team is free to apply the calculation adjustments and hypotheses it deems most appropriate for the objective pursued.’ In other words, since the valuation will not lead to a monetary transaction, the valuation methods that have to be applied by law can be modified. To be more precise, since no real money/transaction is involved, the technical team admits that they consider that they can make adjustments that they deem opportune given the ‘objective pursued’.

It is therefore no wonder that Euroval has not officially endorsed any of the six reports.