Content of the special regime and time of imputation

Amount to be imputed

Regulations: Art. 92.4 Law Income Tax

The amount to be imputed will be the value of the consideration that has been paid prior to the contracting of the labor services of the natural person or that must be paid by the second assignee for the transfer of the right to exploitation or the consent or authorization for the use of the image of the natural person.

This amount will be increased by the amount of the payment on account made by the second transferee on the total amount paid to the first non-resident transferee and will be reduced by the value of the consideration obtained by the natural person of the first transferee as a result of the transfer, consent or authorization of the exploitation of his/her image, provided that said benefit was obtained in a tax period in which the natural person who owns the image was a taxpayer for the IRPF .

The percentage to determine the income on account has been 19% in 2023 (art. 107 Regulation IRPF ).

The imputation of the corresponding amount will be recorded in box [0274] of section "E" of the declaration.

Tax period in which the imputation must be made

Regulations: Art. 92.5 Law Income Tax

The imputation will be made by the taxpayer in the period corresponding to the date on which the employer (second or last transferee) makes the payment or satisfies the agreed consideration, unless for said tax period the natural person was not a taxpayer for this tax, in which case the imputation must be made in the first or last tax period for which he/she must pay this tax, as the case may be.

For these purposes, the exchange rate in effect on the day of payment or satisfaction of the agreed consideration by the second assignee will be used.