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V2275-25 25 November 2025 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · entidad parcialmente exenta

Player development fees subject to Corporate Tax as economic activity

A non-profit sports association seeks advice on the tax treatment of fees received from FIFA for player development rights. The DGT confirms these fees are subject to Corporate Tax as deriving from economic activity.

The question raised

Whether the entity must declare said income in Form 200 of the Corporate Income Tax as non-exempt income and what tax treatment corresponds to this type of income.

The DGT's ruling

Non-profit entities not included in Law 49/2002 are partially exempt entities. Income shall be exempt if it arises from their corporate purpose and does not derive from an economic activity. In this case, income from player training rights is considered taxable and not exempt as it constitutes an economic activity. Likewise, donations or fees intended to finance said economic activity shall also be subject to tax.

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