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A company engaged in property leasing has enquired whether its overheads (professional services, management support, and office costs) are deductible. The Directorate General for Taxes (DGT) has ruled that, as these are general expenses benefiting the economic activity as a whole, they are deductible by applying the pro rata rule.
Cuestión planteada Deducción de gastos generales de su actividad tales como servicios profesionales independientes.
Los gastos generales de la actividad, aunque no tengan una relación directa e inmediata con operaciones sujetas y no exentas, son deducibles si representan un beneficio general para el empresario. Al realizar la entidad operaciones con derecho a deducción (alquiler de locales) y otras sin derecho (arrendamiento de viviendas y terrenos rústicos), la deducción de estos gastos se realizará mediante la aplicación de la regla de prorrata general o especial.
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