Skip to content
Back to index
V1303-25 11 July 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · contrato de aparcería

Income from a shareholding agreement may be classified as income from immovable capital

A retired person asks how to classify income from granting land to a shareholder. The DGT determines that since the owner does not participate in technical direction or organisation of work, the income is classified as income from immovable capital.

The question raised

Classification of the income obtained for the purposes of Personal Income Tax.

The DGT's ruling

Sharecropping contracts generate income from economic activities only if the lessor organizes the means of production or human resources on their own account. If the sharecropper retains technical management of the exploitation and the organization of the tasks, the income is classified as income from real estate capital.

Book your free first meeting