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A query was raised regarding whether the subrogation of employees to a new company results in more than one payer for Income Tax (IRPF) purposes. The Directorate General for Taxes (DGT) ruled that the transferee company maintains the status of the same payer.
Question posed: In the event that subrogations occur, the inquiry concerns the existence of more than one payer for the purpose of determining the obligation to file an income tax return (IRPF).
In cases of personnel subrogation pursuant to the cited railway collective agreements, the transferee company maintains the status of the same payer. Therefore, the threshold for the obligation to file a tax return for employment income shall be 22,000 euros per annum, rather than 12,000 euros.
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