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A beneficiary of a trust asks how loan interests paid to a holding and dividends received should be taxed. The DGT clarifies that income from movable capital is taxed according to its legal holder, and subsequent distributions of already imputed income do not trigger further taxation.
Cuestión planteada Se describen en la contestación a la consulta.
Los rendimientos de capital mobiliario se atribuyen a los contribuyentes que sean titulares de los elementos patrimoniales según las normas de titularidad jurídica. Los intereses de préstamos se integran en la base imponible del ahorro. La devolución del capital prestado no tiene efectos en el IRPF. Las distribuciones de rentas ya sometidas a tributación en el IRPF no quedan sujetas a nueva tributación al ser entregas materiales de fondos ya imputados.
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