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V3128-19 ·11 November 2019 ·consulta-vinculante Medium impact
Tax

Rental income from the transfer of use and enjoyment is attributed entirely to the recipient of the right

A taxpayer was granted the transfer of her husband's share in certain properties through a loan for use agreement (comodato) for the purpose of renting them out. The DGT has determined that, as she receives the proceeds, this constitutes a transfer of rights of use or enjoyment rather than a mere loan for use; consequently, the income is attributed exclusively to her.

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2019-11-11PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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