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V5489-26 ·18 August 2026 ·consulta-vinculante Medium impact
Tax

Corporate tax relief for income from Ceuta or Melilla may apply to dropshipping activities

A company based in Ceuta has requested clarification on whether it can apply the tax relief provided under Article 33 of the Corporate Tax Act when performing e-commerce intermediation services (dropshipping). The Directorate General for Taxes (DGT) has ruled that this relief is applicable, provided the company is domiciled in Ceuta and maintains the necessary material and human resources within that territory.

In 6 key points

How it affects those involved

This ruling confirms that companies engaged in digital intermediation models, such as dropshipping, can benefit from regional tax incentives in Ceuta and Melilla, provided they demonstrate a genuine economic presence and operational substance in those locations.

Lifecycle

2026-08-18PublishedPublished 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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