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V2240-16 ·24 May 2016 ·consulta-vinculante Medium impact
Tax

Joint ownerships are taxed via income attribution rather than Corporation Tax

The applicant asks whether a joint ownership (comunidad de bienes) engaged in retail clothing trade is liable for Corporation Tax. The DGT rules that, as it is a joint ownership and not a civil society with a commercial purpose and fiscal legal personality, it must continue to be taxed through the attribution of income.

In 6 key points

How it affects those involved

This ruling clarifies the distinction between joint ownerships and civil societies, confirming that the lack of a commercial purpose and fiscal legal personality prevents the application of Corporation Tax, maintaining the regime of income attribution.

Lifecycle

2016-05-24PublishedPublished 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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