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A query was raised regarding whether an improper cooperative group without legal personality must file a Corporate Tax return and its status as a taxable person for VAT purposes. The DGT ruled that it is not a Corporate Tax taxpayer, but instead taxes through income attribution, although it is indeed a taxable person for VAT.
Question raised 1. Whether the cooperative group is obliged to file a Corporate Income Tax return.
As it lacks legal personality and constitutes an economic unit or separate patrimony, the cooperative group is taxed under the income attribution regime (art. 86-90 LIRPF). It is not a taxpayer for Corporate Income Tax purposes as it is not one of the entities provided for in art. 7.1 LIS. Nevertheless, it holds the status of a taxable person for VAT purposes by acting as an entrepreneur in its activity. Regarding electronic notifications, the obligation will depend on whether any circumstance of art. 4.2 of RD 1363/2010 applies.
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