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A Spanish tax resident owning property in Italy asks how rental income is taxed and whether Italian IMU payments are deductible in Spanish personal income tax. The DGT states that rental income is capital income subject to Spanish IRPF (without excluding Italy's possible taxation under the Spain-Italy CDI Article 6), and unrented property generates imputed income (Article 85 of the Spanish Personal Income Tax Law). Italian IMU is not analogous to IRPF or IRNR, so no double taxation deduction under Article 80.1 of the LIRPF applies.
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El impuesto municipal italiano (IMU) grava la propiedad de los bienes inmuebles y no constituye un impuesto sobre la renta según el Convenio entre España e Italia. Al no tener una naturaleza idéntica o análoga al IRPF o al IRNR, no cabe la aplicación de la deducción por doble imposición internacional prevista en el artículo 80.1 de la LIRPF.
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