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V3684-20 29 December 2020 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · entidades sin fines lucrativos

Income from training and consultancy in foundations may be exempt if they are auxiliary or of minor relevance

A foundation subject to Law 49/2002 asks whether income from training and consultancy services is subject to Corporate Income Tax. The DGT indicates that, as they are not specifically listed as exempt, their taxation will depend on whether they meet the limits for auxiliary activity or minor relevance.

The question raised

Question posed: Whether the provision of services consisting of training and consultancy that form part of the corporate purpose would be taxed for Corporate Income Tax purposes and whether they would be income subject to Corporate Income Tax.

The DGT's ruling

Training and consultancy services are not specifically categorized under the exempt activities of Article 7 of Law 49/2002. They could be exempt if they are auxiliary or complementary activities that do not exceed 20% of total income, or if they are of minor relevance with a turnover of less than 20,000 euros. Otherwise, the income will be subject to Corporate Income Tax at a rate of 10%.

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