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V0031-26 9 January 2026 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · atribución de rentas

Subsidy income in a person group to be split equally or as per agreement

A taxpayer asks whether a €10,000 subsidy should be fully attributed to them or shared with the other member of their group. The DGT responds that, as the group lacks legal personality, income must be allocated according to the agreement or equally.

The question raised

Whether for Personal Income Tax purposes the subsidy must be attributed in its entirety to the taxpayer or to both members of the group, and what would be the correct method to transfer to the second member of the collaboration agreement the portion of the aid received that corresponds to them.

The DGT's ruling

The status of beneficiary of the subsidy corresponds to the grouping of persons. According to the Personal Income Tax Law (LIRPF), the income of entities without legal personality is attributed to the participants according to the applicable agreements. As there is an agreement establishing an equitable participation in execution and financing, the subsidy must be attributed equally to each member of the grouping.

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