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V2394-24 25 November 2024 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · sociedad civil

Civil societies subject to Corporate Tax are not required to file Form 184

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.

The question raised

Whether the consultant is obliged to file form 184, in addition to its Corporate Income Tax self-assessment.

The DGT's ruling

If a civil society has a commercial purpose and is not subject to the Professional Societies Act, it is a taxpayer for Corporate Income Tax. As a taxpayer of said tax, it is not considered an entity under the income attribution regime for Personal Income Tax. Therefore, it is not obliged to file form 184.

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