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V1882-14 14 July 2014 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · sujeto pasivo

Embassies and foreign representation bodies not required to declare corporate tax or form 347

An embassy or foreign representation body enquired whether it should file corporate tax returns and form 347. The DGT has clarified that it does not qualify as a tax liable entity and is not required to submit form 347 for its extraterritorial activities.

The question raised

Whether it must submit a Corporate Income Tax return and Form 347.

The DGT's ruling

The entity is not a taxpayer for Corporate Income Tax purposes as it is not included in the list provided in Article 7.1 of the TRLIS. Regarding Form 347, there is no obligation to submit the annual declaration of transactions with third parties if the activities performed are extraterritorial, as no business or professional activities are carried out in Spain according to the RGAT.

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