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V2130-14 4 August 2014 · SG de Tributos Locales Criterion in force
OTRO · impuesto sobre actividades económicas

Rental income from properties must be included in business revenue for IAE exemption

A taxpayer inquired whether income from the use of properties leased to related parties should be included in business revenue to qualify for IAE exemption. The DGT responded that such activity is economic and its income must be included in the business revenue calculation.

The question raised

Whether the amount of income from the use of real estate must or must not form part of the calculation of the net amount of turnover for the purposes of applying the tax exemption.

The DGT's ruling

To calculate the net amount of the taxable person's turnover, all economic activities carried out must be taken into account, regardless of whether some are exempt or taxed at a zero rate. Consequently, income from the activity of leasing residential properties must be included in the calculation of turnover for the application of the exemption provided in Article 82.1.c) of the TRLRHL.

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