Consecuencias en el IP de la regularización socio-sociedad en el IRPF: regularización íntegra y sistema tributario. STS de 23 de julio de 2024, rec. 8950/2022

Abstract

This commentary analyzes the doctrine established by the TS ruling of July 23, 2024 (rec. 8950/2022), according to which the  attribution of the income of a company to the individual, as income from its economic activity, determines that the regularization  practiced afterwards by the Comunidad Autónoma in relation to the IP, cannot be limited to eliminating the exemption of the  participations in the entity, and must also reduce the value of the participations. The work addresses the relevance of this ruling  from the point of view of the principle of full regularization and considers that it should have gone further to allow the deduction of  the debt settled by the IRPF in the liquidation for IP.