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V2021-25 29 October 2025 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · entidad parcialmente exenta

Amounts provided by partners for R&D&i projects may be subject to CIT if the existence of economic activity is determined

The DGT rules that payments from partners to fund R&D projects with a technology centre and received subsidies are subject to Corporate Tax and VAT as economic activities, not statutory shares.

The question raised

Regarding Corporate Income Tax, it is requested to determine whether the amounts provided by the partners for the payment of the Technological Center's invoice are exempt or not, as well as the subsidies received by the Association and derived to the partners who participated in the research project. Regarding Value Added Tax, it is requested to determine whether the amounts provided by the partners for the payment of the Technological Center's invoice are exempt or not. Furthermore, it is requested to determine whether there is a possibility to deduct the VAT amounts derived from the invoices received from the Technological Center.

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