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A query was raised regarding whether a joint ownership (comunidad de bienes) engaged in machinery repair should be taxed under Corporation Tax or maintain the income attribution regime. The Directorate General for Taxes (DGT) ruled that, as it is a joint ownership and not a civil society with legal personality and a commercial purpose, it must continue to be taxed through income attribution.
This ruling confirms that joint ownerships lacking legal personality and a commercial object will remain under the income attribution regime, preventing them from being reclassified as entities subject to Corporation Tax.
The tax team reviews your specific situation.
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