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A query was raised regarding whether a civil company with a commercial purpose should be taxed via income attribution or through Corporate Tax. The DGT ruled that, as it possesses a commercial purpose and tax legal personality, it is a taxpayer subject to Corporate Tax.
Question posed: How is the income temporarily generated by the SCP taxed from 01/01/2016 until the date of its transformation into a limited liability company before 30/06/2016? As an attribution of income imputed to each partner according to their percentage, or directly to each partner as income from economic activity.
Civil societies with a commercial purpose and fiscal legal personality are taxpayers of Corporate Income Tax pursuant to Article 7.1.a) of the LIS. To possess fiscal legal personality, they must be constituted by public deed or private document submitted to the Administration to obtain a NIF. A commercial purpose implies performing production, exchange, or service activities for the market, excluding agricultural, livestock, forestry, mining, and professional activities.
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