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A query is made regarding the taxation of partners in a civil society and their reporting obligations. The DGT clarifies that the entity's income is attributed to the partners as income from economic activities and that payments from the society to a partner for their work are not deductible expenses, but rather an increased share in the net income.
Question raised 1) Taxation of the income paid by the society to each of the partners, in the event of application of the direct estimation method and the reporting obligations of the civil society.
Entities under the income attribution regime are not taxpayers; instead, income is attributed to the partners while maintaining the nature of the source (economic activity). Payments to a partner working in the entity are neither employment income nor deductible expenses, but part of the attributable economic activity income. Partners must file Form 130 for the totality of their economic activity income, including that attributed by the entity. For the objective estimation regime, each partner is computed as a non-salaried person, unless they prove a dedication of fewer than 1,800 hours per year.
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