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V2801-14 17 October 2014 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · bonificación

90% Corporate Tax relief applies only to the portion of the tax liability derived from maritime transport

A Canary Islands shipping company has requested clarification on whether the tax relief provided under Article 76 of Law 19/1994 can be applied to the entire tax liability of a 'door-to-door' transport service. The Directorate-General for Taxes (DGT) has ruled that the relief only applies to the portion of the tax base arising from the operation of vessels registered in the Special Register.

The question raised

1) Whether the tax relief provided for in Article 76 of Law 19/1994 can be applied to the entirety of the liability derived from the "door to door" service.

The DGT's ruling

The 90% tax relief applies to the full tax liability (after double taxation deductions) corresponding to the portion of the tax base derived from the operation of vessels registered in the Special Registry of Vessels and Shipping Companies. In globally invoiced services that include maritime and land transport, the tax relief shall not extend to the liability corresponding to land transport. The taxpayer must substantiate the amount of the relief-eligible liability through means of proof admitted under Law.

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