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A query was raised regarding whether two companies belonging to the same group should be classified as patrimonial entities. The DGT ruled that if the group employs at least one worker under a full-time employment contract for leasing purposes, it is considered an economic activity for all entities within the group.
Cuestión planteada Tienen ambas entidades la consideración de entidades patrimoniales.
Para el arrendamiento de inmuebles existe actividad económica si se utiliza al menos una persona empleada con contrato laboral y jornada completa. En grupos de sociedades, el concepto de actividad económica se determina teniendo en cuenta a todas las que formen parte del mismo. No serán entidades patrimoniales aquellas en las que al menos la mitad de su patrimonio esté afecto a dicha actividad económica.
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