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V2132-25 11 November 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos de capital inmobiliario

Rents from rural property rental taxed based on land ownership at any given time

The DGT clarifies that rental income from rural property is considered real estate capital income and is attributed to the owner according to the enforceability of the rent.

The question raised

In view of the future sale of the estate, it is inquired how the outstanding lease rights to be collected must be taxed under Personal Income Tax (IRPF).

The DGT's ruling

Income from the lease of land constitutes income from real estate capital if it is not carried out as an economic activity. This income is attributed to the legal owner of the asset according to the Civil Code. Temporal imputation is carried out in the period in which the rents become due to the recipient. Thus, the seller is taxed on the rents due while they were the owner, and the buyer on those due after the acquisition.

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