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V1645-22 8 July 2022 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · subrogación empresarial

Business subrogation does not imply multiple payers for IRPF declaration limits

A worker inquired whether, following subrogation from one company to another within the same group, she would be considered to have two payers for IRPF purposes. The DGT ruled that, due to the business succession, the transferee 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 under IRPF-2021.

The DGT's ruling

In cases of business succession by subrogation, the transferee company maintains the status of the same payer for the purpose of determining the applicable withholding rate. Therefore, there is no existence of more than one payer for the purpose of determining the threshold for the obligation to file a tax return for income from employment.

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