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V2431-20 ·16 July 2020 ·consulta-vinculante Medium impact
Tax

Entities under the income attribution regime must declare transfer right payments in Form 347

A query was raised regarding whether a payment for a transfer right should be considered a payment made by an entity under the income attribution regime and who is responsible for declaring it in Form 347. The DGT ruled that, as the entity lacks legal personality, the rights belong to the partners, but since the expense relates to the economic activity, it must be declared by the entity.

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2020-07-16PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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