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A Luxembourg company has requested a ruling on whether income derived from a property in Spain (licence fees and rent) can be considered income obtained without a permanent establishment. The Directorate General for Taxes (DGT) has determined that, as no full-time employees are engaged, the income is classified as income from real estate capital rather than income from economic activities.
Cuestión planteada Si puede considerarse que la sociedad consultante obtiene las rentas del inmueble sin mediación establecimiento permanente en territorio español.
Las rentas derivadas de la utilización o arrendamiento de bienes inmuebles en España se consideran rentas inmobiliarias según el CDI. Para que el arrendamiento sea actividad económica, debe utilizarse al menos una persona empleada con contrato laboral y a jornada completa. Al no cumplirse este requisito, las rentas se califican como rendimientos del capital inmobiliario. España tiene derecho a gravar estas rentas de forma ilimitada.
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