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V3599-20 17 December 2020 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · entidades sin fines lucrativos

Training and consultancy activities of a foundation may be exempt if of minor relevance

A foundation subject to Law 49/2002 has enquired whether its logistics training and consultancy activities are exempt from Corporate Tax. The DGT indicates that while these do not appear to fall under professional teaching, they could be exempt if considered economic activities of minor relevance.

The question raised

Question raised 1) Whether the main activity carried out by the Foundation is exempt from Corporate Income Tax.

The DGT's ruling

Income from training and consultancy activities does not appear to fall within the scope of teaching and vocational training under Article 7.17 of Law 49/2002. However, it could be exempt if considered economic activities of minor relevance pursuant to Article 7.12, provided that its turnover does not exceed 20,000 euros. This criterion is subject to the entity complying with all requirements of Law 49/2002.

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