Skip to content
Back to index
V1249-24 30 May 2024 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · subrogación empresarial

No two payers to be considered if duplication arises from business subrogation

A worker inquired whether they have two IRPF payers following a company change caused by a non-monetary contribution of a business line. The DGT ruled that, if business succession exists, the new company maintains the status of the same payer.

The question raised

Inquiry is made regarding the existence of more than one payer for the purpose of determining the obligation to file a tax return under IRPF-2023.

The DGT's ruling

If a succession of business occurs pursuant to the Workers' Statute, the transferee company maintains the status of the same payer for the purpose of determining the withholding tax rate. In this case, there is no existence of more than one payer for the purposes of the obligation to file a tax return for income from employment. Therefore, it is considered a single payer if the requirements for business succession are met.

Book your free first meeting