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A Spanish company asks about the taxation and withholding of payments to non-residents for boat and mooring rentals. The DGT determines that boat rentals are capital movable income and mooring rentals are real estate income.
Cuestión planteada Tributación de las rentas satisfechas. Obligación de retener por parte de ABS Marine Sales SRL.
El alquiler de embarcaciones se considera rendimiento de capital mobiliario para el perceptor no residente. Los rendimientos derivados del alquiler de amarres en puertos son renta obtenida en España por ser derivados de bienes inmuebles o derechos sobre ellos. La entidad residente está obligada a practicar la retención e ingreso a cuenta según el TRLIRNR.
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