According to the described proposal, the main goal of the research project is trying to clarify if, despite the arguments usually employed against personal taxation about riches (IP) and about its transmission (ISD), it could or even should still be considered, with the due legal remodelling, an indispensable complement of charges from the incomes that have their origin in the capital, in view of the deficiencies that appear to be discerned in its treatment in the Personal Income Tax and in the IS from an equity point of view, without harming the advances that could be registered in this field, as the proposed or already implemented measures to an international level give results in order to assure a minimum taxation of the capital transnational incomes.

To that end, the next specific goals and tasks to be accomplished by the research group are proposed:

GOAL NO.1. Analysis of the structural aspects of the charges from the capital incomes in the Spanish tax system.

1. Analysis of the structural aspects of treatment of capital incomes in the Personal Income Tax: problems in equity that proposes the imposed semi-dual character.
   1. Comparative analysis of the treatment of work incomes, company incomes and capital incomes, with particular attention to the difference between the forecast and financial savings.
   2. Analysis of the rules that make possible to differ the integration of capital incomes in the taxable amount.
   3. Dual taxation from the equality and progressiveness principles point of view.
2. Analysis of the structural aspects of the Corporate Income Tax as a genuine tax over the capital incomes.
   1. Treatment of company incomes in the IS depending on the type of company:
      1. SMEs versus big companies.
      2. Social economy companies versus capital societies.
   2. Comparative analysis of the treatment of real estate and financial activities incomes in the IS: patrimonial societies and special systems related to financial and real estate investment (collective investment institutions, SOCIMIs, entities holding foreign securities, venture capital entities...)
   3. International and European taxation factors in the configuration of the taxation about society income: reality and expectative about minimum taxation of the transnational incomes in a digitalisation of the economy context (Globe rules, Directive minimum taxation) and relation to the minimum taxation of the art .30 bis LIS.

Description. With this goal it is pursued the identification of general lines in the evolution and current situation of the incomes taxation derived from the ownership of goods and rights with economic content in two personal taxes that are subdued to charges, meaning, the Personal Income Tax and the IS. In the case of the Personal Income Tax, they will be able to be put to manifest the differential aspects of the juridical system of work, capital and business activities incomes, not only related with the determination of the main tax liability, but also for the purpose of the payment system on account. Two specific issues will receive particular attention. On the one hand, the incidence about equity of treatment of rules that allow differing in the integration time in the imposable basis of patrimonial profits and loss, and on the other hand, the integration and compensation rules in the taxable amount that imprint in the tax only a semi-dual character and its possible collision with the neutrality principle in the charges of company incomes as mixt source incomes. 

GOAL NO.2. Analysis of the interposition of corporations and its influence over the effective charges of capital charges.

1. Analysis of the relations between the IS and the Personal Income Tax from the tax justice point of view: the interposition of corporations as a differentiation strategy in the progressive charges of the capital incomes.
2. Relation between the IS and the Personal Income Tax. inexistence, with a general character, from a correction system of double taxation between IS and Personal Income Tax and significance of the transparency systems.
3. The social economy companies: a symbiotic integration case between Personal Income Tax and IS.
4. The minimum taxation in the Corporate Income Tax as guarantee of a fairest taxation of the undistributed corporate incomes.

Description. With the purpose of reaching this goal, the rules governing the relation between Personal Income Tax and the IS, its influence over capital income taxation and, as a consequence, over the juridical organisation decisions of the economic activities or the mere real estate or financial inversion, will be analysed and systematised. All of it with the purpose of making profit of the advantages, in this case, could result in the retention of capital incomes in the entities patrimony with the goal of delaying its definitive integration in the taxable amount of the Personal Income Tax. To this end, particular attention will be given, on the one hand, to the suppression of the elimination system of the double economic taxation between both taxes and implications that was produced in 2006, on this matter, of the special transparency systems existing in the rules and regulations of the personal taxes over the income. Lastly, the incidence potential over the treatment of capital incomes that the introduction could have and the possible evolution of the named minimum taxation in the Corporate Income Tax, will be analysed.

GOAL NO.3. Analysis of the taxes over the riches and over its transmission such as the complementary taxation of the Personal Income Tax.

1. 3.1Personal taxation over the riches (IP, ISD) versus real taxation in the local field (IBI, IIVTNU, IVTM) from the point of view of taxation justice principles.
2. 3.2Current estate of the imposition over the riches and over its transmission: productive capital treatment (ex., family company system) versus financial and real estate capital treatment, and treatment of savings-prevision against financial savings.
3. 3.3Revision of the arguments against the maintenance of the personal taxation over the riches and over its transmission: The supposed confiscatory scope of taxation over riches.
4. 3.4The functions of the taxation over riches from the taxation justice principles point of view.
5. 3.5Taxation over the riches inside the framework of autonomic funding: current problematic and remodelling proposals.
6. 3.6Proposed alternatives in relation to the taxation over the riches (suppression, maintenance with remodelling or integration of the Personal Income Tax).

Description. Inside this last block, the goal is to analyse and value the multiple arguments employed both in favour and against of the maintenance of the taxation over the riches. This analysis must be done from the taxation justice principles point of view and on the basis of the problematic aspects that its current regulation presents. We are talking, as a last resort, about determining to which extent functions traditionally assigned to these taxations inside the tax system architecture are being accomplished, meaning, if their complementary character of the charges of the capital incomes is still prevailing, or even if it is found more necessary than ever its maintenance, with the necessary remodelling to correct the dysfunctional aspects, or if, on the contrary, they should be replaced by alternatives such as its integration in the Personal Income Tax, as it has been suggested in some of the formulated proposals during the last years.