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A non-resident asks how subsidies received for vineyard restructuring in Galicia should be taxed. The DGT states that, as earnings from economic activity via a permanent establishment, the taxable base is determined under Corporate Income Tax and accounting rules.
Cuestión planteada Forma en que debe tributar esta subvención en el Impuesto sobre la Renta de no Residentes.
Las rentas de la explotación agrícola de un no residente se consideran obtenidas mediante establecimiento permanente y tributan según el régimen general del Impuesto sobre Sociedades. La imputación de la subvención, tanto contable como fiscal, debe realizarse siguiendo los criterios de la norma de registro y valoración 18ª del Plan General de Contabilidad, atendiendo a su finalidad (financiar gastos, adquirir activos o asegurar rentabilidad).
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