Attribution criteria

Regulation: Article 46 LIS

Entities that apply this special regime must make the imputations referred to in the previous sections to the persons or entities that hold the economic rights inherent to the status of partner or member company on the day of the conclusion of the tax period of the entity subject to said regime, in the proportion that results from the statutes of the entity.

As regards the moment of imputation it must be distinguished:

• If the partners are also subject to this special regime, the imputation will be made on the end date of the tax period of the entity in which they participate.

• In other cases, the imputation will be made in the following tax period, unless it is decided to do so continuously on the same date of the end of the tax period of the entity subject to this regime.

  The option will be stated in the first tax return in which it is to take effect, which will remain in effect for three years.

  Remember:

  Members of Spanish or European economic interest groups or temporary business unions must express the option in the section «B. Attribution criterion art. 46.2 LIS” in the table “Participants in economic interest groups and UTE ” on page 24 bis of model 200.