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An individual transfers full ownership of several properties to her daughters through an improvement pact, subject to a condition precedent regarding the power to dispose of and encumber the assets. The DGT rules that the imputation of income must be attributed to the daughters as the owners, rather than the transferor.
Cuestión planteada - Imputación de las rentas inmobiliarias correspondientes a los inmuebles objeto del pacto de mejora.
La imputación de rentas inmobiliarias procede a las hijas en su condición de titulares del pleno dominio de los inmuebles. La transmitente no debe realizar la imputación porque no es titular de los inmuebles ni de derechos reales de disfrute. Al haberse transmitido el pleno dominio sin reserva de usufructo, la transmitente no obtiene rendimientos del capital inmobiliario.
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