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The taxpayer, currently resident in Spain, was a non-resident during 2017-2020. The Administration regularised those years by directly attributing the profits of their non-resident company as own income, taxed in IRNR. Now, the company is distributing those same profits as dividends. The DGT rules that no IRPF tax is due on these amounts, as they have already been taxed in IRNR.
Cuestión planteada Si el consultante debe tributar por los referidos dividendos en su Impuesto sobre la Renta de las Personas Físicas.
Cuando los beneficios de una sociedad han sido regularizados por la Administración Tributaria e imputados directamente al socio, y este ya ha tributado por ellos en el IRNR, su posterior distribución como dividendos no genera una nueva obligación tributaria en el IRPF. La calificación fiscal otorgada por la regularización prevalece, evitando la doble imposición sobre las mismas rentas.
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