Skip to content
Back to index
V0551-26 10 March 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · actividad económica

Rental of homes via outsourcing constitutes economic activity

A company asked whether renting 160 homes through an external manager constitutes economic activity and whether it qualifies for the special rental regime. The DGT ruled that outsourcing management does not preclude economic activity, and access to the special regime depends on compliance with legal requirements.

The DGT's ruling

The existence of economic activity in the leasing of real estate is not excluded by subcontracting management to an external and independent entity. The requirement to have personnel with employment contracts and full-time working hours may be satisfied by subcontracting material and human resources to third parties outside the group. For the special regime for residential leasing, the entity may benefit from it if it meets the requirements of Article 48 of the LIS, which will depend on the assessment of the facts.

Book your free first meeting