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A requesting entity inquired whether a company intended to be established to provide payment services and operate ATMs should be taxed at the general rate or the credit institution rate. The DGT ruled that, as it is a payment institution and not a credit institution, the general rate applies.
Cuestión planteada Si a la entidad que se pretende constituir le será de aplicación el tipo de gravamen general.
Las entidades de pago cuya definición y régimen jurídico no coinciden con el de las entidades de crédito no tributarán al tipo del 30 por ciento previsto para estas últimas. Por tanto, no les resulta de aplicación el artículo 29.6 de la LIS, sino el tipo general de gravamen.
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