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V0069-18 17 January 2018 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · club de inversión

Investment clubs managing exclusively members' assets are subject to income attribution taxation

A query was made regarding the tax regime applicable to an investment club established to invest in futures and manage its members' assets. The Directorate General for Taxes (DGT) indicates that such entities are subject to the income attribution regime.

The question raised

Tax regime applicable to the investment club.

The DGT's ruling

If the investment club exclusively performs the management of its members' assets, the income shall be attributed to the partners in accordance with the provisions of the Personal Income Tax Act. The attributed income shall have the nature derived from the activity or source from which it originates for each partner. The calculation of the income shall be carried out in accordance with the rules of the Personal Income Tax.

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