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V2207-25 17 November 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · régimen especial de desplazados

Property income under displaced workers regime declared at full amount

A taxpayer under the displaced workers special regime asks whether property income should be declared at net or full amount. The DGT confirms it must be declared at full amount, as expenses cannot be deducted.

The question raised

1. Manner of calculating real estate capital income subject to taxation under the special regime: are the income subject to taxation the gross income or the net income (income minus deductible expenses)?

The DGT's ruling

For taxpayers subject to the special regime under Article 93 of the LIRPF, the possibility of deducting expenses provided for in Article 24.6 of the TRLIRNR is not applicable. This is because said deduction is exclusive to residents in other Member States of the European Union, whereas the subjects of this special regime are residents in Spain. Therefore, the income is determined by its gross amount.

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