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V2236-24 ·15 October 2024 ·consulta-vinculante Medium impact
Tax

Sociedad with 9 rental properties and no full-time employee not deemed to have economic activity for corporate tax purposes

A company established in 2016 with non-resident shareholders manages 9 rental properties generating approximately €70,000 annually in revenue, without any full-time employee. The DGT concludes there is no economic activity for corporate tax purposes as it fails to meet the requirement under Article 5.1 of the LIS: rental property activity only constitutes economic activity when at least one full-time employee is employed under a labour contract, and the scale of the business does not justify outsourcing.

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2024-10-15PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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