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A landowner receives reservation premiums before a lease for rural land begins. The DGT has determined that these amounts are refundable advances and must be taxed only when the lease becomes effective.
Cuestión planteada Tributación de las referidas "primas de arrendamiento".
Si el arrendamiento no es actividad económica, las primas de reserva se consideran anticipos reintegrables. Al estar condicionada su percepción al inicio del arrendamiento, la imputación de los rendimientos de capital inmobiliario debe realizarse en el momento en que este comience. Los pagos derivados de una eventual devolución del anticipo no tienen efectos en la renta.
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