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A public business entity has enquired whether the fees it receives for issuing guarantees should be subject to withholding tax for Corporation Tax. The DGT has ruled that, as the issuance of guarantees forms part of its economic activity, these fees are not considered income subject to withholding.
Cuestión planteada 1. Si el abono a la consultante por parte de la entidad financiera de la comisión anual por riesgo del aval concedido al beneficiario conlleva retención en concepto de pago a cuenta del Impuesto sobre Sociedades de la consultante.
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