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A query was raised regarding how partners of an agricultural civil society should be taxed when all manage the entity but only one provides personal labour. The DGT ruled that the income retains its nature as an economic activity for all partners.
Question posed: Classification for Personal Income Tax purposes of the amounts received by the partners of the civil society.
The civil society is not a taxpayer for Corporate Income Tax purposes when performing agricultural activities. The income is attributed to the partners while maintaining its nature as income from economic activities, provided that the organization of production means or human resources corresponds to the entity. The fact that only one partner contributes personal labor does not prevent the others from exercising organizational functions, so all are holders of the economic activity.
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