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The query asks whether bareboat ship leasing constitutes an economic activity and whether this prevents a company from being considered a patrimonial entity. The DGT responds that, if the necessary resources are available, such activity is economic and the accumulated cash is considered a tied asset.
Question posed: Whether the activity consisting of bareboat vessel leasing can be classified as "economic" under the terms established in Article 5.1 of the Corporate Income Tax Law (LIS) and, if so, whether it could be confirmed that the company MFF does not have the status of a patrimonial entity.
Bareboat leasing may constitute an economic activity if there is an organization of production means and human resources. To determine whether a company is a patrimonial entity, the treasury and short-term financial assets accumulated through the ordinary development of the economic activity are considered affected elements. If the treasury resulting from said activity represents more than half of the assets, the entity shall not be considered a patrimonial entity.
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