Skip to content
Back to index
V3000-16 28 June 2016 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · sociedad civil

Partnerships engaged in livestock farming are not subject to Corporation Tax

A query was raised regarding whether a partnership (comunidad de bienes) engaged in livestock farming is liable for Corporation Tax. The Directorate General for Taxes (DGT) ruled that, as it is engaged in livestock farming, it lacks a commercial purpose and continues to be taxed through the attribution of income.

The question raised

Whether the consulting company will be a taxpayer for Corporate Income Tax purposes.

The DGT's ruling

To be a taxpayer for Corporate Income Tax purposes, a civil society must possess legal personality and a commercial purpose. A commercial purpose is understood as the performance of production, exchange, or service activities within a sector not excluded from the commercial sphere. Agricultural, livestock, forestry, mining, and professional activities are excluded. Therefore, property communities with livestock activities are taxed through the attribution of income to their members.

Book your free first meeting