Back to index
V2469-19 16 September 2019 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · entidad parcialmente exenta

Income from player training fees is subject to Corporation Tax if it constitutes an economic activity

A non-profit sports association has enquired whether training fee income from a player is exempt from tax. The DGT has ruled that, as it forms part of its corporate purpose and involves the organisation of resources to provide services, it is considered an economic activity and is therefore subject to tax.

The question raised

Whether the fee received by the consulting entity should be treated as exempt or non-exempt income for the purposes of the provisions of Article 110 et seq. of Law 27/2014, of November 27, on Corporate Income Tax.

The DGT's ruling

Income from non-profit entities is exempt if it arises from their corporate purpose and does not constitute economic activities. However, income derived from player training is considered taxable and not exempt if it involves the organization of material or human resources for the provision of services. Membership fees for which no consideration is received could be considered exempt.

Book your free first meeting