Skip to content
Back to index
V0346-25 19 March 2025 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · actividad económica

Lease of real estate constitutes economic activity even if management is subcontracted

The DGT confirms that three property leasing entities carry out economic activity under the LIS, as professional management subcontracting does not negate the requirement of economic activity.

The question raised

Whether, in accordance with the provisions of article 5.1 of Law 27/2014, of 27 November, on Corporate Income Tax, it can be considered that entities A, B, and C carry out an economic activity.

The DGT's ruling

For the leasing of real estate, the LIS requires at least one person with an employment contract and full-time working hours to consider that an economic activity exists. However, if management is subcontracted to specialized entities to achieve efficient professional management, the requirements of article 5.1 of the LIS may be met. Furthermore, as they are part of the same business group, the concept of economic activity shall be determined taking into account all entities that form part of the same group.

Book your free first meeting