Spain Income Tax Return 2025 (IRPF): Complete Guide for Taxpayers
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Athlete image rights: Art. 92 LIRPF and special tax treatment in Spain
Athletes can assign their image rights to a company for tax advantages. We analyse Art. 92 LIRPF, the 85% limit, the 24% withholding on international assignments and simulation risks.
Table of contents
The special regime of Art. 92 LIRPF
Art. 92 LIRPF allows income from image rights assigned through a company to be taxed at a flat 19% corporate tax rate instead of the athlete's progressive personal income tax.
The 85% limit
The special regime only applies if image income does not exceed 85% of the athlete's employment income. If this threshold is exceeded, the athlete includes image income in their personal tax return.
24% withholding on international assignments
When the club assigns rights to a foreign entity, a 24% withholding applies on amounts paid (Art. 92.8 LIRPF).
Simulation risks
The tax authority analyses whether the company has real economic substance. If the assignment is fictitious, it declares simulation and adjusts the athlete's IRPF with a 50-150% penalty.
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