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V4600-16 ·28 October 2016 ·consulta-vinculante Medium impact
Tax

Fishing activities deemed outside the commercial sphere and subject to the income attribution regime

A query was raised regarding whether the production and marketing of mussel farming (mejillón en batea) constitutes a commercial activity subject to Corporate Tax or Personal Income Tax (IRPF). The Directorate-General for Tax (DGT) ruled that fishing activities fall outside the commercial sphere and, therefore, the entity must be taxed under the income attribution regime.

In 6 key points

How it affects those involved

This ruling clarifies the tax classification for certain fishing activities, ensuring they are treated under income attribution rather than corporate taxation.

Lifecycle

2016-10-28PublishedPublished 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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