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V2937-19 ·23 October 2019 ·consulta-vinculante Medium impact
Tax

Contributions to commercial companies do not count towards fulfilling general interest purposes

A foundation sought clarification on whether contributions to two commercial companies (Special Employment Centres) could be considered funds allocated to its general interest purposes. The Directorate-General for Tax (DGT) ruled that they cannot, as these companies do not qualify as non-profit entities under Law 49/2002.

In 6 key points

How it affects those involved

This ruling clarifies that investments in commercial entities, even those with social objectives like Special Employment Centres, do not satisfy the requirement for funds to be directly dedicated to a foundation's non-profit purposes for tax purposes.

Lifecycle

2019-10-23PublishedPublished 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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