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V2859-15 5 October 2015 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · cesión de cartera de clientes

VAT accrues upon the transfer of the client portfolio and Personal Income Tax may be imputed based on collections if the price is deferred

A professional transferring their client portfolio for a variable price based on future profits asks when the amounts must be declared. The DGT indicates that VAT accrues at the time of the transfer and that, for Personal Income Tax, the gain may be imputed according to collections if the price is deferred.

The question raised

Question posed: The timing at which the amounts received must be declared for Value Added Tax and Personal Income Tax.

The DGT's ruling

VAT accrues when the transfer of the portfolio is carried out, and a provisional amount must be established if the consideration is unknown. For Personal Income Tax, the transfer of the portfolio generates a capital gain or loss. If the price is deferred and received in successive payments over more than one year, the taxpayer may impute the income as the collections are made.

Apply this to a real case

What is published here, applied to a company or a specific case. The first meeting is free.

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