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V1110-25 25 June 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · subrogación empresarial

No more than one payer in corporate succession for IRPF declaration

A cleaning worker asks whether, after a 2024 corporate succession, they must declare IRPF due to having two payers. The DGT responds that, due to succession, the new business owner retains the status of the same employer and there is only one payer.

The question raised

Question raised: For the purpose of determining the obligation to file the 2024 Personal Income Tax (IRPF) return, the question concerns the determining limit of said obligation.

The DGT's ruling

In cases of business subrogation, the transferee maintains the status of the same employer for the purpose of determining the applicable withholding rate. Therefore, there is no existence of more than one payer for the purposes of the obligation to file a tax return. The applicable limit is 22,000 euros per annum for income from employment.

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