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The inquiry concerns the impact on Personal Income Tax (IRPF) of a 'unit-linked' life insurance contract where the inquirers contribute assets but are neither policyholders nor beneficiaries. The DGT determines that no income from movable capital is generated for them and that the transfer of assets between the companies involved does not affect their IRPF.
Question posed: Inquiry regarding the impact on IRPF for the inquirers 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. Furthermore, a transfer of assets between sister companies, whether direct or indirect through insurance, produces no effects on the IRPF of the individual shareholders, as they are external to the transaction between the companies.
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