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A query was raised regarding whether property leasing can be considered an economic activity for Corporate Income Tax purposes. The DGT ruled that this requirement is met even if management is carried out through outsourcing rather than by employing own staff.
Question posed: Whether the activity of leasing real estate can be classified as an economic activity for Corporate Income Tax purposes.
For the leasing of real estate to constitute an economic activity, the Corporate Income Tax Act requires the employment of at least one person under an employment contract working full-time. However, if the management of a significant real estate portfolio is subcontracted to specialized companies, the requirement for economic activity is deemed to be met. In this instance, subcontracting replaces the need to hire own personnel for business organization.
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