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V2725-16 ·15 June 2016 ·consulta-vinculante Medium impact
Tax

Joint ownerships are not subject to Corporation Tax unless they are civil societies with a commercial purpose

The applicant asks whether a joint ownership (comunidad de bienes) dedicated to art restoration, the sale of antiques, and the operation of a rural house is liable for Corporation Tax. The DGT rules that, as it is a joint ownership and not a civil society with a commercial purpose, it remains subject to the income attribution regime.

In 6 key points

How it affects those involved

This ruling clarifies the distinction between joint ownerships and civil societies, confirming that the former are subject to personal income tax through income attribution rather than corporate taxation, provided they lack a commercial purpose.

Lifecycle

2016-06-15PublishedPublished 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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