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V3134-14 19 November 2014 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
OTRO · entidad sin ánimo de lucro

Rents from cultural events by an association may be taxable under IS, VAT and IAE

A non-profit association seeks advice on the taxation of a contract with a municipality to organise a traditional dance event. The DGT states that if the association organises its own resources, the income may be considered an economic activity subject to taxation.

The question raised

Taxation for the purposes of Corporate Income Tax, Value Added Tax, and Business Activity Tax.

The DGT's ruling

In Corporate Income Tax, income shall not be exempt if it derives from an economic activity through the management of production means and human resources. Regarding the Business Activity Tax, the entity shall be subject to it if it carries out activities involving such management, such as the organization of parties or artistic performances. In VAT, the activity is subject to tax if the aid is consideration for services, although it could be exempt if the association is a social entity that carries out musical or choreographic performances.

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