Skip to content
Back to index
V1674-26 19 June 2026 · SG de Fiscalidad Internacional Criterion in force
IRNR · sociedad civil inmobiliaria

Real estate societies in France not liable for imputed rental income from unoccupied properties in Spain

A French real estate society (SCI) asks whether it must pay Spanish tax on periods when its properties in Spain are unoccupied. The DGT confirms that, as a legal entity, no imputed rental income arises from simply holding unoccupied properties.

The DGT's ruling

Spain has the authority to tax income from real estate located within its territory according to the Convention with France. However, the imputation of income from urban real estate not used for economic activities only applies when the taxpayer is a natural person. As the inquirer is a company, the imputation of income does not apply during periods of vacancy.

Book your free first meeting