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V2859-16 ·22 June 2016 ·consulta-vinculante Medium impact
Tax

Joint ownerships are taxed via income attribution if they lack legal personality and a commercial purpose

A query was raised regarding whether a joint ownership (comunidad de bienes) engaged in operating a bar-café should be subject to Corporate Tax. The DGT ruled that, as it does not meet the requirements of legal personality and a commercial purpose, it continues to be taxed under the income attribution regime.

In 6 key points

How it affects those involved

This clarification confirms that joint ownerships without a commercial purpose remain outside the scope of Corporate Tax, maintaining their status under the income attribution regime for tax purposes.

Lifecycle

2016-06-22PublishedPublished 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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