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V0894-22 26 April 2022 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · entidades sin fines lucrativos

Income from economic activities of non-profit entities may be exempt from Corporate Tax

An association has requested a ruling regarding the Corporate Tax exemption on income derived from its therapy and service activities. The DGT clarifies that exemption depends on whether the activities align with the entity's social purpose or are considered ancillary or of minor relevance.

The DGT's ruling

If the entity is a public utility association that meets the requirements of Law 49/2002, income from economic activities shall be exempt if they are carried out in fulfillment of its specific object or purpose, such as healthcare or social inclusion. Activities that do not fulfill the corporate purpose shall only be exempt if they are ancillary (not exceeding 20% of total income) or of minor relevance (turnover of less than 20,000 euros). Membership fees and grants are exempt provided they do not finance non-exempt economic activities.

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