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An entity inquired whether it could transfer funds to an athlete derived from income that the Administration had already imputed to them. The DGT ruled that, as said income had already been imputed to the athlete, the transfer of funds has no tax impact for either party.
Cuestión planteada Si es correcto que la entidad consultante transfiera la titularidad de los fondos en los que se materializaron tales rentas al deportista sin impacto fiscal para ninguna de las dos partes.
Dado que la Administración tributaria ya ha considerado que las rentas obtenidas por la entidad son imputables al deportista como rendimientos de su actividad económica, la posterior transferencia de la titularidad de los fondos al deportista no debe tener impacto fiscal ni en la entidad ni en el propio deportista. Esto se debe a que dichas rentas ya han sido imputadas fiscalmente al beneficiario.
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