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V2193-18 ·24 July 2018 ·consulta-vinculante Medium impact
Tax

No imputation of imputed real estate income for the use of parking spaces and storage rooms derived from an administrative concession

A query was raised regarding whether the use of a garage and a storage room obtained through an administrative concession from a local council should be taxed as imputed real estate income under Personal Income Tax (IRPF). The Directorate General for Taxes (DGT) ruled that this right of use is not a real right of enjoyment and is not covered by Article 85 of the Personal Income Tax Law (LIRPF).

In 6 key points

How it affects those involved

This ruling clarifies that rights of use granted via administrative concessions do not trigger the imputation of real estate income, as they do not constitute real rights of enjoyment under the current tax framework.

Lifecycle

2018-07-24PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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