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The taxpayer asks whether subleasing an industrial warehouse acquired through leasing constitutes an economic activity or income from movable capital. The DGT states that it will only be considered an economic activity if there is an organisation of production means and human resources. If it is not an economic activity, only financial interest may be deducted while the property is leased.
This ruling clarifies the distinction between economic activities and movable capital income for tax purposes, specifically regarding the deductibility of expenses in subleasing arrangements.
The tax team reviews your specific situation.
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