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V1499-24 18 June 2024 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · subrogación empresarial

Business subrogation does not constitute multiple payers for IRPF filing limits

A query was raised regarding whether the subrogation of employees under a collective agreement implies having more than one payer for determining the obligation to file an IRPF tax return. The DGT ruled that, due to the nature of subrogation, the new company maintains the status of the same payer.

The question raised

Inquiry regarding the existence of more than one payer for the purpose of determining the obligation to file a tax return for IRPF-2024.

The DGT's ruling

When the duplication of employers arises from a business subrogation, whether by company succession or by the mandatory application of a collective bargaining agreement, the transferee company maintains the status of the same payer. Therefore, the 15,000 euro limit for having multiple payers does not apply, but rather the limit of 22,000 euros per year for the obligation to file a tax return is maintained.

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