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A civil society providing insurance consultancy and management services enquired whether it was required to file Form 184 in addition to its corporate tax return. The DGT ruled that, as it is a Corporate Tax taxpayer, it is not an entity subject to the income attribution regime.
Cuestión planteada Si la consultante está obligada a presentar el modelo 184, además de su autoliqudiación del Impuesto sobre Sociedades.
Si una sociedad civil tiene objeto mercantil y no está sometida a la Ley de Sociedades Profesionales, es contribuyente del Impuesto sobre Sociedades. Al ser contribuyente de dicho impuesto, no tiene la consideración de entidad en régimen de atribución de rentas en el IRPF. Por tanto, no tiene la obligación de presentar el modelo 184.
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