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V2774-17 ·27 October 2017 ·consulta-vinculante Medium impact
Tax

Joint ownerships taxed via income attribution if they lack legal personality and commercial purpose for Corporate Tax

A query was raised regarding whether a joint ownership (comunidad de bienes) engaged in electrical installations should be taxed under Corporate Tax or via income attribution. The DGT ruled that, as it is not a civil society possessing legal personality and a commercial purpose, it must continue to be taxed under the income attribution regime.

In 6 key points

How it affects those involved

This ruling clarifies the distinction between joint ownerships and civil societies, reinforcing that the absence of legal personality and a commercial objective prevents the application of Corporate Tax.

Lifecycle

2017-10-27PublishedPublished 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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