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V1063-22 11 May 2022 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del capital mobiliario

Income from movable capital is attributed to the period in which it becomes due, not when collected

A query was raised regarding when income from movable capital must be declared for Personal Income Tax (IRPF) purposes. The Directorate General for Tax (DGT) has ruled that temporal attribution is governed by the moment the income becomes due for the recipient.

The question raised

Temporal attribution in Personal Income Tax (IRPF) of income from movable capital.

The DGT's ruling

According to Article 14 of Law 35/2006, income from movable capital is attributed to the tax period in which it becomes due to the recipient. Therefore, if the income is due according to the contractual conditions in a given year, it must be attributed to that period, regardless of whether the actual payment is made in the following year.

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