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V1650-18 12 June 2018 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · pagadores

The existence of multiple payers is not considered if there is subrogation in the ownership of a Registry

An employee of a Land Registry asks whether a change in the ownership of the Registry during the year implies having two payers for the purposes of the IRPF filing threshold. The DGT responds that, due to the subrogation of employment relationships, the new owner maintains the status of the same payer as the previous one.

The question raised

Question posed: Given that there were two different owners of the Registry in 2017, the question concerns whether these should be considered one or several payers for the purpose of determining the obligation to file for the 2017 tax period, also taking into account that withholdings on employment income have continued to be carried out by the new owner under the same terms as previously applied.

The DGT's ruling

The new owner of a Registry maintains the status of the same payer as the outgoing owner for the purposes of determining the applicable withholding rate. The subrogation of employment relationships prevents the existence of more than one payer for the purposes of the obligation to file a tax return. Therefore, the threshold for not filing is 22,000 euros per year for income from employment.

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