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V2469-25 11 December 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · atribución de rentas

Communities of goods taxed under rental attribution regime in IRPF

The DGT confirms that a community of goods carrying out rental and advisory activities must follow the rental attribution regime since it is not a commercial society subject to Corporate Tax.

The question raised

Question posed: A request to confirm whether the community of property may be taxed under the income attribution regime of Personal Income Tax.

The DGT's ruling

Communities of property are not considered taxpayers for Corporate Tax. Only civil societies with a commercial purpose and fiscal legal personality are taxpayers for Corporate Tax. Therefore, communities of property are taxed through the attribution of income to their members in accordance with the LIRPF.

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