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V1028-23 26 April 2023 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · imputación de rentas inmobiliarias

No imputation of real estate income for a rustic warehouse essential for farm exploitation

A co-owner of rural land inquires whether they must impute income for a warehouse built to store tools and harvests. The DGT indicates that if the construction is essential for agricultural exploitation, no imputation of income is required.

The question raised

Question raised: They request to know whether it is appropriate to impute real estate income for said warehouse under the terms of Article 85 of the Personal Income Tax Law.

The DGT's ruling

The imputation of real estate income is not applicable to constructions on rustic properties that are indispensable for the development of agricultural, livestock, or forestry exploitations, provided they are not assigned to economic activities nor generate capital yields. The assessment of whether the warehouse is indispensable for the exploitation is the responsibility of the management and inspection bodies of the Tax Administration.

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