Who can avoid paying the municipal capital gains tax after the government's legal limbo?

Today, 10 November, the modification of the regulations to make the municipal capital gains tax legal and constitutional came into force. Specifically, Royal Decree-Law 26/2021 of 8 November adapts the tax to the successive declarations of unconstitutionality. As the regulation does not have retroactive effects, it may mean that many more taxpayers will be able to avoid paying the tax and, conversely, that local councils will lose more revenue than initially expected.The new regulation designed by the Ministry of Finance does not have retroactive effects, as established in the Third Final Provision of the Royal Decree-Law: "This Royal Decree-Law will enter into...