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V2960-20 1 October 2020 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
OTRO · entidad parcialmente exenta

Association income may be exempt from Corporation Tax, while awards may be subject to VAT if the recipient is a professional

A cultural association seeks clarification on the taxation of funds received for a project and for the awarding of prizes. The DGT analyses Corporation Tax, VAT, and Personal Income Tax (IRPF) applicable to the beneficiaries.

The question raised

Question raised: Information is requested regarding the taxation for Value Added Tax and Corporate Income Tax purposes of the amount delivered to the consulting entity, both the amount allocated to the execution of the project and the amount invested in delivering the awards to the winners.

The DGT's ruling

In Corporate Income Tax, income shall be exempt if it arises from the entity's purpose and not from an economic activity. In VAT, transfers to finance the project do not appear to constitute consideration for services, whereas awards shall be subject to tax if the beneficiary is an entrepreneur or professional. In Personal Income Tax, prizes are considered income from employment or from economic activities depending on the work being rewarded.

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What is published here, applied to a company or a specific case. The first meeting is free.

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