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V2243-25 25 November 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · imputación de rentas inmobiliarias

Rental income must be imputed for holiday let properties when unoccupied

A property owner asks whether rental income must be imputed for a property used for holiday lettings. The DGT confirms that imputation is required when the property is not let.

The question raised

It requests to know whether the imputation of imputed real estate income is applicable regarding the property intended for holiday rentals for the purposes of Personal Income Tax.

The DGT's ruling

The imputation of imputed real estate income is based on the availability of the property and not on its effective use. Article 85 of the Personal Income Tax Law (LIRPF) only excludes the primary residence and cases of allocation to economic activity, generation of capital income, properties under construction, or properties unused due to urban planning reasons. As the case does not meet these exceptions, the imputation applies to the property intended for holiday rentals during the periods it is not rented.

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