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V3553-15 17 November 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · bonificación

Rental income from properties in Ceuta qualifies for corporate tax bonus

A business association asks whether a Ceuta-based company engaged in property leasing can benefit from the corporate tax bonus under Article 33 of the LIS. The DGT confirms that rental income from properties in these territories is considered earned in Ceuta and thus eligible for the bonus.

The question raised

Question posed: Whether the income obtained by this entity may benefit from the tax relief provided in Article 33 of the LIS.

The DGT's ruling

Income obtained from activities that determine the closing of a commercial cycle with economic results in Ceuta or Melilla is considered to be obtained in said territories. For the leasing of real estate located in these territories, this requirement is considered fulfilled. Therefore, an entity domiciled in Ceuta that is engaged in the leasing of real estate in said territory may apply the tax relief provided in Article 33 of the LIS.

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