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V2021-25 ·29 October 2025 ·consulta-vinculante Medium impact
Tax

Amounts provided by partners for R&D&i projects may be subject to CIT if the existence of economic activity is determined

The DGT rules that payments from partners to fund R&D projects with a technology centre and received subsidies are subject to Corporate Tax and VAT as economic activities, not statutory shares.

In 6 key points

How it affects those involved

Such transactions are considered economic activities and are therefore taxable under Corporate Tax and VAT, not exempt as statutory shares.

Lifecycle

2025-10-29PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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