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An owner of an agricultural estate inquired whether the advance collection of four annual installments from a business lease allowed for the application of the reduction for income with a generation period exceeding two years. The DGT responds that the anticipation of payments does not modify the generation period of the income.
Question posed: Consideration of payments made as income with a generation period exceeding two years or obtained in a notoriously irregular manner over time, for the purposes of applying the reduction established in the Personal Income Tax (IRPF) regulations for such types of income.
The leasing of a business is considered income from movable capital. The agreement to make several annual installments due in advance in a single payment does not modify the generation period of the income. As there is no generation period exceeding two years and the income is not obtained in a notoriously irregular manner, the 40% reduction is not applicable.
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