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A query was raised regarding whether a corporate restructuring involving the succession of a productive unit results in the existence of two separate payers for Personal Income Tax (IRPF). The Directorate General for Taxes (DGT) ruled that the transferee company maintains the status of the same payer.
Question posed: Inquiry is made regarding the existence of more than one payer for the purpose of determining the obligation to file an IRPF tax return (2019).
In cases of business succession, the transferee company maintains the status of the same payer for the purpose of determining the applicable withholding rate. Therefore, there is no existence of more than one payer regarding the obligation to file a tax return for employment income when workers transfer to the new workforce.
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