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An inquirer asks about the impact on their Personal Income Tax (IRPF) regarding a 'unit-linked' life insurance contract where contributions are made by entities in which they are a shareholder. The DGT determines that, as they are neither the policyholder nor the beneficiary, they do not obtain income from movable capital, and that the transfer of assets between the companies does not affect their IRPF.
Question posed: Inquiry is made regarding the impact on the inquirer's IRPF of the aforementioned insurance contract.
If the inquirer is neither the policyholder nor the beneficiary of the insurance, they do not obtain income from movable capital pursuant to Articles 14.2 h) and 25.3 of the LIRPF. Likewise, a transfer of assets between sister companies, whether direct or indirect through insurance, produces no effects on the IRPF of individual shareholders, provided that no other legal qualification of the facts is deduced.
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