Chapter 10. Special procedures: imputation and attribution of income

Regulations: Art. 6.2 e) Law Income Tax

Along with the 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 goal is to achieve full identification between the taxable base and the economic capacity of the taxpayer, thereby ensuring maximum efficiency in the application of the progressivity of the IRPF

The materialization of income imputations as Tax Law presumes to be derived from the ownership of certain urban real estate and, on the other, by making the taxpayer partner or participant pay taxes on income obtained through interposed 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 attribution regime
3. Imputation of income of Spanish and European economic interest groups and temporary business associations
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 in collective investment institutions established in tax havens
8. Special scheme: Capital gains from change of residence
9. Case study