El modelo dual de impuesto sobre la renta. Rasgos específicos del caso español

Abstract

Until the last decade of the 20th century, the configuration of personal income tax in developed countries was synthetic in nature, subjecting the tax base, defined by the taxpayer’s combined income, to a progressive rate. At the beginning of the nineties, Scandinavian countries conceived a new model of configuration for this rate known as the dual income tax model, basically consisting in grouping yields in two different tax bases: one for capital yields and earnings from property and another for work yields, also levying them in a different manner. The income tax reform in Spain, introduced by law 35/2006, confirmed the markedly analytical nature that has been applied to this tax in our country since 1996, in a process that embodies one of the great reforms that has distorted its initial configuration.
In this study we carry out an approximation of the theoretical dual income tax model, addressing questions such as its origin, the reasons that gave rise to its creation and implementation, the general characteristics and main arguments for its justification, as well as the distinctive features that it presents in Spanish personal income tax. We also make references to the influence on its dual nature made by the modifications proposed in the recent Report from the Committee of Experts for the Reform of the Spanish Tax System and the Draft Bill which modifies Law 35/2006, on Personal Income Tax.