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The inquiry concerns who is liable for tax in a loan to a developer. The DGT clarifies that the taxable person varies depending on the type of security: if it is a mortgage, the lender is liable; if it is another type of security interest, the borrower is liable; and if there is no security or only personal security, no tax liability arises.
Cuestión planteada 1.- Determinar quién es el sujeto pasivo, si la entidad financiera o el promotor.
Si el préstamo tiene garantía hipotecaria, el sujeto pasivo es el prestamista. Si la garantía es distinta de la hipotecaria (como prenda o anticresis), se aplica la regla general y el sujeto pasivo es el prestatario. En préstamos sin garantía o con garantía personal, la operación no está sujeta al impuesto. No es posible aplicar exenciones por analogía si la operación está sujeta.
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