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V1177-24 23 May 2024 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · entidades sin fines lucrativos

Income from sporting events may be exempt from Corporation Tax depending on nature and limits

A public utility association has requested clarification on whether income from sporting events (races, tournaments, classes) is exempt from Corporation Tax. The DGT indicates that exemption depends on whether these constitute sporting services, sporting shows, or ancillary activities.

The question raised

Whether the services provided by the applicant to natural persons participating in the sporting events organized by the association itself, such as community races, solidarity marches, walks, sporting tournaments, classes, and other sporting events, are exempt from Corporate Tax pursuant to the provisions of Article 7.10 of Law 49/2002.

The DGT's ruling

Sports practice services for non-professional natural persons are exempt if they do not constitute sporting events. Public tournaments are considered sporting events and are not exempt. The organization of events such as a 'sports festival' will only be exempt if it is an ancillary activity (not exceeding 20% of total income) or of minor relevance (not exceeding 20,000 euros).

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