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A taxpayer requested clarification on how to classify income derived from leasing a coffee-bar business, which includes premises, machinery, and equipment. The DGT determined that, as it constitutes a patrimonial unit with its own independent existence, it is classified as a business lease.
This ruling clarifies that leasing a functional business unit, rather than just individual assets, results in income being taxed as movable capital rather than business activity income.
The tax team reviews your specific situation.
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