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A query is made regarding to whom the rental income and the imputed income from real estate correspond when usufruct and bare ownership exist. The DGT responds that both concepts must be attributed to the usufructuary.
Question posed: To whom does the imputation of income from leased real estate correspond, as well as the imputation of real estate income in the case of unleased real estate.
The returns on real estate capital derived from leasing are attributed to the usufructuary, as they have the right to receive the civil fruits of the assets. Likewise, the imputed income from the real estate must be imputed to the holder of the real right of usufruct. In both cases, the attribution is carried out according to the rules of legal ownership and the right of enjoyment.
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