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The applicant inquired whether a partnership (comunidad de bienes) providing agricultural and livestock services is liable for Corporate Tax. The Directorate General for Taxes (DGT) ruled that, as they are engaged in agricultural and livestock activities, they are excluded from the commercial sphere and will continue to be taxed under the income attribution regime.
This ruling clarifies that partnerships performing non-commercial agricultural or livestock activities remain outside the scope of Corporate 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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