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V1181-19 28 May 2019 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · atribución de rentas

Income from entities under the income attribution regime retains the nature of the economic activity

A query was raised regarding how income should be attributed and what reporting obligations entities under the income attribution regime that carry out an economic activity have. The DGT clarifies that partners receive income with the same nature as the entity's activity and that they must submit Form 184.

The question raised

Method of attributing returns obtained to its members and information obligations.

The DGT's ruling

Entities under the income attribution regime are not taxpayers, but rather groupings of partners to whom income is attributed according to its original nature. If the entity carries out an economic activity, the attributed returns maintain that character, provided that the entity organizes the means of production or human resources on its own account and the partners assume the business risk. Attribution is carried out according to agreements or, in their absence, in equal parts, and the entity must file the informative tax return Form 184 and notify its members of the total income and the attributable income.

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