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The owner and usufructuary of land leased for a wind farm inquired whether the 30% reduction could be applied to a lump-sum payment received for the impact on infrastructure. The Directorate General for Taxes (DGT) ruled that this reduction is not applicable.
Cuestión planteada Aplicación de la reducción del 30 por ciento a dicha contraprestación.
La contraprestación por la afección de infraestructuras no está vinculada a un periodo de tiempo de generación del rendimiento. Al no existir un periodo de generación superior a dos años ni tratarse de rendimientos calificados reglamentariamente como notoriamente irregulares, no procede la reducción del 30% prevista en el artículo 23.3 de la LIRPF.
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