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V4129-16 26 September 2016 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · sociedad civil

Civil societies with livestock farming activities are not subject to Corporation Tax

A query was raised regarding whether a civil society dedicated to livestock farming is liable for Corporation Tax. The DGT ruled that, as livestock farming is considered outside the scope of commercial activity, the entity is not a taxpayer for this tax and continues to be taxed through the attribution of income.

The question raised

Whether the consulting entity will be a taxpayer for Corporate Income Tax.

The DGT's ruling

To be a taxpayer for Corporate Income Tax, a civil society must have a commercial purpose, understood as activities of production, exchange, or services in a non-excluded sector. Agricultural, livestock, forestry, and mining activities are considered outside the commercial scope. Therefore, civil societies performing these activities are not taxed under Corporate Income Tax, but rather through the income attribution regime under Personal Income Tax.

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