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The applicant inquired whether a partnership (comunidad de bienes) engaged in the buying and selling of livestock is liable for Corporation Tax. The DGT ruled that, as it is engaged in livestock farming, it lacks a commercial purpose and continues to be taxed under the income attribution regime.
This ruling clarifies that partnerships involved in primary agricultural activities, such as livestock farming, remain outside the scope of Corporation Tax, maintaining their status under the income attribution regime rather than being treated as commercial entities.
The tax team reviews your specific situation.
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