Skip to content
Back to index
V2187-25 17 November 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · subrogación empresarial

Succession of business by subrogation does not imply multiple payers for IRPF

The DGT responds that, in the case of a business succession by subrogation, the new company retains the status of the same payer.

The question raised

Inquiry regarding the existence of one or more payers for the purpose of determining the obligation to file a tax return for Personal Income Tax.

The DGT's ruling

If a business succession occurs pursuant to Article 44.1 of the Workers' Statute, the transferee company maintains the status of the same payer. This means that for employees, there is no plurality of payers for the purpose of determining the threshold for the obligation to file a tax return for income from employment. Tax liability extends to the successor in ownership of the business operation.

Book your free first meeting