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V4438-16 ·17 October 2016 ·consulta-vinculante Medium impact
Tax

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

A query was raised regarding whether a joint ownership (comunidad de bienes) engaged in the street vending of fruit and vegetables is liable for Corporation Tax. The DGT ruled that, as it is a joint ownership and not a civil society with 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 with commercial purposes, ensuring that non-commercial joint ownerships remain subject to personal income tax through income attribution rather than corporate taxation.

Lifecycle

2016-10-17PublishedPublished 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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