How the DGT's position has evolved
Current position
Income from the assignment of intellectual property rights is classified as employment income if there is no self-organization of means of production or human resources. If the author performs self-publishing or manages their own means, the income is considered income from economic activities. In the case of heirs, the receipt of these rights is classified as income from movable capital.
The DGT's position remains constant in the distinction between employment income and economic activities based on the organization of means. A repeated application of the criterion of autonomy of means is observed to differentiate the nature of the income. There are no changes in doctrine, but rather a uniform application of IRPF (Personal Income Tax) regulations to different scenarios such as self-publishing or the role of an evaluator.
Turning points
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Establishes that the self-publishing of a work by its creator transforms the income into economic activities, differentiating it from the assignment of rights to third parties.
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Determines that the income received by heirs is classified as income from movable capital.
Analysis based on 59 of 61 rulings with a stated position. Updated 18 September 2026.