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A farmer received personal aid intended to provide capital to a civil society company of which he is a partner. The DGT has determined that, as the grant was awarded on an individual basis, the income belongs to the applicant personally and not to the civil society company.
Cuestión planteada Si la ayuda concedida se debe imputar al consultante o a la sociedad civil.
Si la resolución de concesión establece que la subvención se otorga a título individual a la persona física, el ingreso debe considerarse ingreso propio del beneficiario para el IRPF. No se aplica el régimen de atribución de rentas de las sociedades civiles previsto en el artículo 8.3 de la Ley 35/2006, ya que no se estableció la condición de beneficiaria de la sociedad civil.
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