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A hotel owner agreed to reimburse rental costs to its tenant. Upon selling the hotel, the new owner will pay this amount to the tenant on behalf of the seller. The DGT determines that this payment constitutes part of the consideration for the transfer and is subject to VAT.
Cuestión planteada Si el pago de dicho importe que va a realizar la entidad adquirente del hotel a la entidad arrendataria se encontrará sujeto al Impuesto sobre el Valor Añadido.
La base imponible de la transmisión del hotel debe incluir el importe de las deudas asumidas por el adquirente que deba satisfacer a la entidad arrendataria por cuenta de la entidad consultante. Este importe se considera parte de la contraprestación de la operación sujeta al impuesto.
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