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V0685-25 15 April 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · subrogación empresarial

Subrogation does not create multiple payers

A worker asks whether she must declare income from three different companies through successive subrogations. The DGT responds that, under corporate subrogation, the new company retains the status of the same payer.

The question raised

Inquiry is made regarding the existence of one or more payers for the purpose of determining the obligation to file the IRPF-2024 tax return.

The DGT's ruling

When the multiplicity of employers derives from business subrogations, the transferee company maintains the status of the same payer for the purpose of determining the applicable withholding tax. Therefore, there is no existence of more than one payer for the purposes of the threshold for the obligation to file a tax return. In this case, the threshold for the obligation to file remains at 22,000 euros per annum.

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