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A non-profit nautical club inquired whether income from the transfer of mooring rights to its members is exempt from Corporation Tax. The DGT ruled that, as it involves the organisation of means and resources to provide a service, it constitutes an economic activity subject to tax.
Question posed: Whether the income obtained by the Club from the granting of use to its members during the concession period of the mooring points is exempt from Corporate Income Tax.
Non-profit entities that are not of public utility are partially exempt entities. The exemption does not extend to income from economic activities, understood as the organization of production means and human resources to produce or distribute goods or services. The granting of the right to use mooring facilities to members involves such organization of means; therefore, the derived income constitutes an economic activity and is subject to tax.
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