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Practical Income Manual 2020.

Chapter 10. Special procedures: imputation and attribution of income

Regulations: Art. 6.2 e) Law Personal Income Tax

Along with income (from work, capital and economic activities) and capital gains and losses, the third component of the taxpayer's income is made up of the income imputations established by law .

Income imputations constitute a special tax regime whose ultimate purpose is to achieve full identification between the tax base and the economic capacity of the taxpayer, thereby ensuring maximum effectiveness in the application of the progressivity of Personal Income Tax

The materialization of income imputations as a tax category is carried out by incorporating, on the one hand, income that the Personal Income Tax Law presumes to be derived from the ownership of certain urban real estate and, on the other hand, , making the taxpayer partner or participant pay taxes on the income obtained through intermediary entities.

The Personal Income Tax Law , under the name of special regimes, incorporates the following categories of imputation and attribution of income:

  1. Real estate income imputation regime
  2. Income allocation regime
  3. Allocation of income from Spanish and European economic interest groups and temporary business unions
  4. Imputation of incomes in the international tax transparency scheme
  5. Imputation of income from the transfer of image rights
  6. Special regime for workers posted to Spanish territory
  7. Imputation of income by partners or participants of collective investment institutions established in tax havens
  8. Special scheme: Capital gains due to change of residence
  9. Practical case